REVIEW OF THE
RURAL WATER PROGRAMME 2003-2006
VALUE FOR MONEY AND POLICY REVIEW INITIATIVE
December 2007
Executive Summary (see glossary of terms p.7.)
Introduction
In November 2002, the European Court of Justice ruled that Ireland was in contravention of
the EU’s Drinking Water Directive mainly due to the substandard quality of drinking water on
privately sourced community owned Group Water Schemes. The Court threatened to impose
substantial fines on the Irish State if this situation was not resolved without delay.
Action Plan for Rural Drinking Water Quality 2003-2006
In response, the Department of the Environment, Heritage and Local Government initiated a
major programme of capital upgrade works under the Action Plan for Rural Drinking Water
Quality 2003-2006. This programme comprised five water quality upgrade solutions,
involving either connection to the public water mains or the construction of standalone water
treatment facilities, where public mains connection was not a viable technical option.
Review Methodology
This Review assessed the implementation, effectiveness and cost efficiency of the €298
million invested overall, under each of the five upgrade solutions as well as other capital
measures, over the 2003-’06 period. This was achieved by taking an overview of programme
implementation based on data collected in a questionnaire completed by all County Councils,
implementing this devolved local authority programme. More detailed analysis of efficiency
and effectiveness was carried out by examining a selection of upgraded schemes, under each
solution type. The most recent EPA water quality test results for upgraded Group Schemes
were checked to verify that they are now effectively complying with the Directive.
Conclusions
This Review found that while programme implementation to date has been substantial, there
has been slower progress on the two solutions, involving connection to the public mains.
According to local authority questionnaire returns, the unwillingness of some non-domestic
Group Scheme consumers to pay for local authority water appears to lie at the heart of this
delay in many cases. Councils have been granted additional enforcement powers under the
2007 Drinking Water Regulations to take remedial action, if necessary, on such Schemes.
Although the Disinfection/Sterilisation upgrade solution was very cost efficient, schemes in
1
two out of four Counties examined continued to report exceedances of the Drinking Water
Directive’s microbiological and chemical parameters, after being upgraded under this
solution. Some Schemes upgraded under the Non-DBO solution also showed inconsistent
effectiveness post upgrading. The Disinfection/Sterilisation and Non-DBO solutions have
been designated respectively for 17% and 3% of all Schemes. In both cases, inadequate
maintenance of water treatment infrastructure by some Group Scheme volunteers may be the
problem. Local authorities should insist that, as a minimum, members of such Group Schemes
attend the Group Scheme maintenance courses run by the Water Services National Training
Group (WSNTG). The DBO treatment plant solution and the two solutions involving
connection to the public mains were found to be effective. 72% of new Group Schemes built
during the 2003-’06 period were publicly sourced with the number of newly constructed
privately sourced group schemes decreasing each year. This is an encouraging sign as the
EPA regards the quality of public drinking water as generally satisfactory. The DBO
treatment plant solution was found to be the most expensive treatment solution but was the
only viable technical option in cases, where the raw water chemistry was not appropriate for
disinfection/sterilisation or connection to the public mains was not possible. The practice of
procuring several DBO treatment plants together in bundles appears to have been successful
in attracting more competitively priced bids for these bigger contracts. The cost of pipe
network upgrades was found in many cases to exceed the cost of water treatment upgrades for
all treatment solutions and it is essential that future such expenditure is carefully targeted.
Recommendations
The programme of water quality upgrades, required to comply with the Drinking Water
Regulations, must be completed without delay to protect the public health of Group Water
Scheme householders. It is also important that the Department reminds Councils that while a
partnership approach with the Group Schemes’ sector is vital for programme implementation,
the ‘most economically advantageous’ effective treatment approach must ultimately continue
to be adopted in the interests of the taxpayer. There also needs to be a greater focus by
Councils on source protection measures, particularly for newly constructed Group Schemes,
to avoid a recurrence of water quality problems in the future requiring expensive remedial
State investment. The Conclusions and Recommendations of the Rural Water Programme
Review are set out in Chapter 7 on p.192. and proposed performance indicators on p. 175.
2
TABLE OF CONTENTS
Executive Summary
Page 1
Table of Contents
Page 3
List of Appendices
Page 4
Terms of Reference
Page 5
List of Abbreviations
Page 6
Glossary of frequently used terms
Page 7
Chapter 1
Introduction to the Rural Water Programme
Page 8
Chapter 2
Literature Review
Page 30
Chapter 3
Methodological Approach
Page 56
Chapter 4
Findings and Analysis
Page 70
Chapter 5
Future Funding Needs/Alternative Approaches
Page 163
Chapter 6
Proposed Performance Indicators
Page 175
Chapter 7
Conclusions and Recommendations
Page 192
Appendices
Page 213
Bibliography
Page 241
3
List of Appendices
Appendix 1
Breakdown of Relevant Group Schemes by County
Appendix 2
Membership of National Rural Water Monitoring Committee
Appendix 3
National Federation of Group Water Schemes (NFGWS) response to
questions re. Rural Water Programme Value for Money Issues
Appendix 4
Circular L9/2006 and Questionnaire to Local Authorities re. Rural Water
Value for Money Review
Appendix 5
Drinking Water Regulations – Water Quality Parameters
Appendix 6
Estimated Non-Domestic Water demand for DBO Bundles
Appendix 7
Provisional Design Build Costs for completed DBO Bundles
Appendix 8
Ryan Hanley Submission re. Leakage Control
Appendix 9
Membership of Review Steering Group
4
Terms of Reference for Value for Money Review of the Rural Water Programme
The Value for Money (VFM) Review of the Rural Water Programme during the period of the
Action Plan for Rural Drinking Water Quality 2003-2006 will:
1) Identify programme objectives.
2) Examine the current validity of those objectives and their compatibility with the
overall strategy of the Department of the Environment, Heritage and Local
Government.
3) Define the outputs associated with the programme activity and identify the level and
trend of those outputs.
4) Examine the extent that the programme’s objectives have been achieved, and
comment on the effectiveness with which they have been achieved.
5) Identify the level and trend of costs associated with the Action Plan for Rural Drinking
Water Quality 2003-2006 and thus comment on the efficiency with which it has
achieved its objectives.
6) Evaluate the degree to which the objectives warrant the allocation of public funding on
a current and ongoing basis and examine the scope for alternative policy or
organisational approaches to achieving these objectives on a more efficient and/or
effective basis.
7) Specify potential future performance indicators that might be used to better monitor
the performance of future Action Plans for Rural Drinking Water Quality.
8) The core objective of the Action Plan for Rural Drinking Water Quality 2003-2006 is
to bring the Group Water Schemes sector into compliance with the terms of the
European Communities (Drinking Water) Regulations 2000. Therefore, the Small
Public Water and Sewerage Scheme and Well Grant elements of the Rural Water
Programme will not be reviewed as part of this study as their objectives are not
directly related to the Group Water Schemes sector.
9) As the administration of the Rural Water Programme is largely devolved to local
authorities, the efficiency and effectiveness of the local government system in meeting
the objectives of the Action Plan for Rural Drinking Water Quality 2003-2006 will be
assessed.
5
List of Abbreviations
BMW
CCMA
CPI
CRF
CTPM
DB
DBO
DWD
ECJ
EPA
ERDF
EU
GWS
M&E
NDP
NFGWS
NPV
NRWMC
O+M
P/E
PMS
PPP
PPP
PWS
RWP
S&E
THM
ToR
UFW
VFM
WSNTG
Border, Midlands and Western Region
City and County Managers’ Association
Consumer Price Index
Capital Replacement Fund
Connection to the Public Mains
Design Build
Design Build Operate
Drinking Water Directive
European Court of Justice
Environmental Protection Agency
European Regional Development Fund
European Union
Group Water Scheme
Mechanical and Electrical
National Development Plan
National Federation of Group Water Schemes
Net Present Value
National Rural Water Monitoring Committee
Operation and Maintenance
Population Equivalent
Project Programme Management System
Public Private Partnership
Polluter Pays Principle
Public Water Supplies
Rural Water Programme
Southern & Eastern Region
Trihalomethanes
Terms of Reference
Unaccounted For Water
Value-for-Money
Water Services National Training Group
6
Glossary of frequently used terms
Client Representative
Consulting Engineers jointly employed by the DBO Bundle Group
Schemes and County Council to procure and oversee the work of the
DBO operator during the Design Build phase of the contract
Compliance
Compliance with the water quality parameters of the Drinking Water
Regulations 2000
Cost per House
The capital cost of a Group Scheme’s water treatment solution and/or
pipe network upgrade divided by the number of houses connected to
the Group Water Scheme
DBO Operator
Consortia contracted to design and build the water treatment plants in
a DBO Bundle and operate the plants for 20 years
Design Capacity
The maximum amount of water that the plant is designed to treat
Drinking Water
Regulations, which came into effect on January 1st 2004, transpose the
Regulations 2000
EU’s Drinking Water Directive into Irish law. The Drinking Water
Regulations 2007 recently superceded the 2000 Regulations
DBO Bundle
A number of water treatment plants serving individual Group Water
Schemes procured together as one contract
DBO Sub-bundle
Two or more Group Water Schemes being served by the same water
treatment plant within a DBO Bundle contract
ECJ Ruling
2002 European Court of Justice (ECJ) ruling that Ireland’s private
water supplies i.e. Group Schemes are in contravention of the
Drinking Water Directive
Groundwater
Water sourced from underground aquifers.
Group Water Scheme
Private entities involving two or more premises abstracting water from
a common water source and sharing a pipe distribution system
Network Upgrade
Upgrade works relating to the water pipe distribution network
Operation and
Fixed and Volumetric Costs involved in treating Group Scheme water
Maintenance
and maintaining the pipe distribution network
Parameters
Minimum water quality standards categorised into microbiological,
chemical and indicator parameters
Private GWS
Group Water Scheme served by a private water source
Public GWS
Group Water Scheme connected to the public mains
Rationalisation
The merger of two or more Group Schemes into a single legal entity
to be served by a single treatment plant
Raw Water
Untreated source water
Source Protection
Measures to protect source of drinking water supplies
Subsidy
Annual payment to Group Schemes to subsidise the domestic
household portion of the operational costs of Group Water Schemes
Surface Water
Lake or River Water Sources
Treatment Solution
Upgrade works relating to improving water quality
Unaccounted for
Water that is lost out of the water distribution system through leakage
Water (UFW)
and wastage
7
Chapter 1
Introduction to the Rural Water Programme
8
Background to the Group Water Schemes’ Programme
The Group Water Schemes’ Programme was introduced in 1962 to provide capital grant aid to
rural dwellers for the construction of water distribution systems to pipe water from local water
sources such as lakes or boreholes into their homes and farms. Communities set up voluntary
co-operative structures known as Group Water Schemes to privately manage these water
distribution systems with current operating costs being funded through contributions from
Group Scheme members. Groups varied in size from a minimum of two houses sharing a
water connection to the same source to over a thousand houses in some cases (Dept of
Finance 1989, p1.) The number of Group Water Schemes increased throughout the 1960s,
facilitated by the rural electrification programme, which provided the power to pump water
(Fitzpatrick Associates 2005, p.9). Many of these new Group Schemes were connected up to
the public water mains but retained control over their pipe distribution network. There are
now estimated to be over 5,500 Group Water Schemes in Ireland serving up to 300,000
households (Fitzpatrick Associates 2005, p.11).
The twin objectives of the Group Water Schemes Programme, from its inception, were
quantity and quality. The quantity objective was to provide a sufficient quantity of piped
water in as many houses as feasible. The quality objective was to ensure that water provided
was of a suitable quality for drinking water (Dept of Finance 1989, p.2.). Any uncertainty as
to the definition of suitable drinking water quality was removed with the enactment into Irish
legislation in 1988 of the European Communities (Quality of Water intended for Human
Consumption) Regulations (ibid, p.3). The allocation and payment of capital grants under the
Group Water Schemes’ Programme was administered centrally by the then Department of the
Environment. Departmental inspectors provided technical advice to Groups and certified
completed works for payment. In most counties, the local authorities’ role was minimal and
was generally limited to approving water sources, the designs of Group schemes and liaising
with Departmental inspectors (ibid, p.6-7.). Existing Group Schemes were also entitled to
receive second grants in cases where the existing water supply had become ‘seriously
deficient’ due to capacity constraints or a decline in water quality (ibid, p.5). Since 2002, the
Department of Community, Rural and Gaeltacht Affairs also provides ‘top up’ capital grants
to Group Water Schemes in Clár areas (Fitzpatrick Associates 2005, p.36.).
9
Devolution of the Group Water Schemes Programme
In January 1997, the Minister for the Environment announced that responsibility for the
operation and administration of the Group Water Schemes’ Programme was to be devolved to
local authorities (Circular L1/97). The Department would continue to pay block capital grants
to local authorities but the appraisal and approval of applications for individual Group
Scheme capital grants was solely a matter for the relevant County Council with no
Departmental involvement.
Group Water Scheme Subsidy
In 1997, the Government abolished public water charges for domestic households and instead
funded the operational costs of supplying treated water through the Local Government Fund
(LGF). In the interests of equity, the Government also introduced a subsidy payment to Group
Scheme households to cover the operating cost of providing for their domestic water needs.
The payment is made directly to Group Schemes rather than individual householders by local
authorities. The statutory basis for this scheme is Section 26 of the Local Government
(Sanitary Services) Act, 1948. The annual domestic subsidy rates per household were
increased to their current levels on 28th March 2000.
The current subsidy levels are 100% of the qualifying expenditure as approved by the local
authority, subject to a limit of:-
-
€50.79 for each house in a Group Scheme supplied from a local authority source;
-
€ 101.58 for each house in a Group Scheme supplied from a private source
-
€196.81 for each house in a Group Scheme where water disinfection and/or treatment
is provided under a Design, Build, Operate (DBO) contract or where the water
disinfection/treatment plant is operated and maintained by a contractor by way of a
bona fide Operational and Maintenance Contract.
The conditions for the domestic subsidy scheme are set out in a Subsidy Explanatory
Memorandum issued by the Department. Two of the eligibility conditions for the Group
10
Scheme subsidy are that it is providing a supply of water for domestic purposes which is, in
the opinion of the local authority, satisfactory, and water conservation measures are being
actively implemented (Department of the Environment, Heritage and Local Government
2002).
National Rural Water Monitoring Committee and the Rural Water Programme
In February 1998, the Minister for the Environment and Local Government launched the
Rural Water Programme with substantially increased capital provision for the improvement of
rural water systems, with a strong focus on improved drinking water quality (NRWMC 2003,
p.1). In May 1998, the Minister established the National Rural Water Monitoring Committee
(NRWMC) “to advise the Minister on national policy on rural water services and to monitor
the implementation, by local authorities, of the devolved rural water programme” (Preface,
NRWMC – June 1999). The NRWMC comprises all the main stakeholders in the Rural Water
sector including central and local government officials, farming organisations and most
crucially the National Federation of Group Water Schemes (NFGWS) as representatives of
the Group Water Schemes sector. The Department has developed a partnership approach in
working with the NFGWS to meet the objectives of the Rural Water Programme. The member
organisations of the National Rural Water Monitoring Committee are listed in full in
Appendix 2. In March 2000, the Minister announced new capital grant structures for water
quality upgrades based on advice from the NRWMC. The current capital grant levels are set
out in Departmental Circular L11/04.
Rural Water Strategic Plans
The NRWMC “began a process of strategic planning for rural water supply and water quality
in 1999” (NRWMC, foreword, May 2002). All County Councils were required to draw up
Strategic Rural Water Plans for supplying rural water needs in their county and upgrading
water quality. The NRWMC issued Strategic Plan guidance documentation to all County
Councils in June 1999 and May 2002. County Councils were required to identify the most
suitable water quality upgrading solution for Group Schemes in their area in consultation with
the Group Scheme members. Both versions of the Strategic Guidance documentation
specified that Councils should cost and consider all water quality upgrade options and select
the most ‘economically advantageous’ solution (June 1999, p.2.15 & May 2002, p.4.7). Local
11
Monitoring Committees were also established to monitor water quality issues on a County
basis.
The 1998 Drinking Water Directive and 2002 European Court of Justice Ruling
On the 14th November 2002, the European Court of Justice (ECJ) ruled that Group Water
Schemes serving more than 50 people (i.e. more than 15 houses) fell within the terms of the
new 1998 Drinking Water Directive, which was due to come into effect under Irish law on 1st
January 2004. This case had been originally initiated against Ireland for contravention of the
previous Drinking Water Directive. This ruling had particular consequences for Group Water
schemes with private water sources i.e. non-local authority water supply as the quality of the
water in many of these schemes was not compliant with the new Directive. In its 2002 ruling,
the ECJ found that 453 Group schemes serving more than 50 persons were non-compliant. A
subsequent June 2006 Report to the European Commission, based on the latest local authority
data, found that there were in fact 729 Group Schemes in Ireland each serving more than 50
persons, which required upgrading. A county breakdown of the 729 Schemes is provided in
Appendix 1. The remainder of the estimated 5,500 Group Schemes in Ireland (Fitzpatrick
Associates 2005, p.11.) are either already connected to the public mains and receiving good
quality water or are exempted from compliance with the Drinking Water Regulations, due to
their small size.
In the event of non-compliance with the Drinking Water Directive, Ireland could receive
substantial fines from the European Court of Justice. These fines could include both a lump
sum fine equalling the cost savings to Ireland from not investing in the necessary water
treatment infrastructure to make Group Schemes compliant as well as a daily fine for each day
that the Group Schemes remain non-compliant. Substantial fines were imposed on Spain in
November 2003 for failing to comply with the Bathing Water Directive. Most significantly of
all in Case C-304/02 of 2005, “the ECJ ordered France to pay both a penalty payment of
€57,761,250 for each period of six months, from the 12th July 2005 onwards and a lump sum
of €20,000,000 for not adequately enforcing EU rules in relation to the sale of undersize fish.”
The potential size of the financial penalties that could be imposed on Ireland means that the
full implementation of the required water quality upgrades on Group Water Schemes is now a
national priority for the Irish Government. Further information on ECJ fines is available at
12
(http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/05/482&format=HTML&a
ged=0&language=EN&guiLanguage=fr) .
Action Plan for Rural Drinking Water Quality 2003-’06
In response to the ECJ Ruling, the National Rural Water Monitoring Committee (NRWMC)
prepared an Action Plan for Rural Drinking Water Quality 2003-’06. This Plan identified a
number of upgrading solutions for the non-compliant Group Water Schemes serving more
than 50 persons. Local authorities were requested to identify and oversee the implementation
and upgrading of each of the relevant Group Schemes using the most appropriate water
quality upgrade solution.
Water Quality Upgrade Solutions
729 Group Water Schemes serving 89,570 houses are being upgraded under this Action Plan.
The National Rural Water Monitoring Committee and County Councils have identified five
water treatment solutions for 584 of these 729 schemes, three of which involve stand-alone
treatment and two of which involve connection to the public water supply. All of these 584
Schemes are receiving their water from private sources. The remaining 145 Schemes are
Group Schemes, which are already connected to a local authority water source but have water
quality problems in their distribution network.
Stand-alone Treatment Solutions

Water Schemes is Design Build
Operate (DBO) water treatment. where a single service provider / contractor designs,
builds and operates water treatment facilities for schemes over a 20-year period. The
Group Water Scheme continues to be responsible for the operation and maintenance of
the pipe network distribution system.

The proposed solution for 21 schemes (3%) is the construction or upgrading of an
existing non-DBO water treatment plant. The Group Water Scheme continues to be
responsible for the operation and maintenance of the water treatment infrastructure
and pipe network distribution system.
13

where the chemistry and quality of the private schemes source is appropriate. The
Group Water Scheme continues to be responsible for the operation and maintenance of
the water treatment infrastructure and pipe network distribution system.
Solutions involving connection to the public water supply

nnected to public supply, while retaining their status
as a group water scheme. The Group Water Scheme continues to be responsible for
the operation and maintenance of the pipe network distribution system and pays the
local authority for the public water supply.

65 schemes (9%) are to be taken in charge by the Local Authority. These Group
Schemes will cease to exist after takeover and its members will be treated as public
Public Source Schemes

145 schemes (20%) are already connected to the public water mains. These substandard public source Group Water Schemes will either receive pipe network
upgrades or be taken over by their local authority.
The above information is illustrated in the pie chart below (June 2006 Report, p.23.)
14
Implementation Status of Group Water Schemes by upgrade solution category
The implementation status of each of the water quality upgrading solutions as of June 2006 is
itemised in the table below. Data was not compiled in this format previously for the 729
schemes so it is not possible to track scheme implementation from 2003 to 2006. This report
does, however, provide a snapshot in time of implementation to date. Updated
implementation figures became available in May 2007 after completion of this Review and
are detailed on p.195.
Table 1.1
Implementation Status of Group Water Schemes by upgrade solution category
Treatment Solutions
DBO
Non-DBO
Connect to Public Main
Council Takeover
Disinfection/Sterilisation
Public Source
Total No. of Schemes
% implementation
% Solution In
Work in Upgrades Total
% Upgrades
breakdown Planning Progress Complete Schemes complete
35%
3%
16%
9%
17%
20%
100%
19
7
85
35
19
21
209
9
27
27
11
15
30
5
6
3
92
109
258
21
118
65
122
145
186
26%
298
41%
245
34%
729
12%
24%
5%
5%
75%
75%
Ref. Figures derived from June 2006 Report to the European Commission on Measures to bring Group
Water Schemes into compliance with the Drinking Water Directive
Response of the European Commission
The European Commission recognises that Ireland is taking significant steps to comply with
the Drinking Water Directive but regards implementation progress to date as unsatisfactory.
In an April 2006 letter, the Commission reminded the Irish Government that substantial
financial penalties in terms of lump sums and daily fines could be imposed on Ireland for noncompliance with the Directive. The European Commission wrote to the Irish Government on
21st March 2007 to deliver a reasoned opinion that Ireland had failed “to take all necessary
measures to comply with the judgement of the Court of Justice of the European Communities
of 14th November 2002, case C316/00 Commission v Ireland, concerning drinking water”.
The Commission reminded the Government of the financial penalties that the European Court
of Justice (ECJ) may impose on a member state, which fails to comply with its judgement.
15
“When the Commission refers a case to the Court of Justice, it specifies the amount of the
lump sum, of the penalty or of both, to be paid by the Member State concerned, which it
considers suited to the circumstances”.
The European Commission based its opinion on the water quality compliance data available
in the 2007 EPA Drinking Water Quality Report. It should be noted though that this report is
based on 2005 data, which doesn’t reflect implementation of upgrading works since then.
Ireland has so far avoided court penalties by demonstrating that it is actively seeking to meet
the terms of the Drinking Water Directive. A revised implementation report, which updates
the June 2006 report to the European Commission, was sent to Brussels in May 2007 to
respond to the Commission’s reasoned opinion. However, until such time as all the relevant
schemes meet all the minimum water quality criteria, Ireland will technically be in breach of
this Directive.
Water Services Act 2007
Progress to date on the Action Plan has been due to the voluntary co-operation of most Group
Schemes with the Rural Water Programme, under the leadership of the National Federation of
Group Water Schemes (NFGWS). There are still, however, a substantial minority of Group
Schemes, who are not co-operating with the Rural Water Programme or the NFGWS and have
not agreed to implementation of the water quality upgrading solutions identified for their
scheme. A Water Services Act was passed by the Oireachtas in May 2007 and provides for a
statutory licensing system for the Group Water Scheme sector for the first time. This licensing
system provides local authorities with the legal means to require privately owned Group
Water Schemes to observe drinking water standards.
The agreement of all Group Scheme members is currently required to have a Scheme taken
over by its local authority. This has created delays in taking over Schemes, were one or more
members objected to Council takeover. The new Water Services Act provides for legal
takeovers based on the agreement of two thirds of Group Scheme members. The National
Rural Water Monitoring Committee is also placed on a statutory footing as the National Rural
Water Services Committee to provide advice to the Minister on rural water policy. County
Councils were already empowered to take prosecutions against non-co-operative Group
16
Schemes under the 2000 Drinking Water Regulations, which transposed the Drinking Water
Directive into Irish law. Councils have been given additional enforcement powers under the
recent 2007 Drinking Water Regulations to take direct remedial action on Group Schemes,
without members’ consent, if necessary, and to be financially recouped by the Group Scheme.
Current position
It is clear that there has been a major shift in the focus of the Rural Water Programme since
the late 1990s. Up to 1998, the main objective of the Group Water Schemes programme was
to fund the provision of infrastructure to provide piped water to rural dwellers with water
quality as a secondary objective. The 1998 Rural Water Programme, however, placed a
stronger emphasis on rural water quality. The Action Plan for Rural Drinking Water Quality
2003-’06 lists the quality of drinking water in rural areas as its highest priority. The current
Rural Water Programme Action Plan outcome i.e. objective is to ensure that the water
coming out of household taps in the 729 Group Water Schemes meet EU drinking water
quality standards. The programme inputs is the capital expenditure incurred on the various
water quality upgrade solutions as well as investment in pipe network distribution system
upgrades. The Programme outputs are the completion of infrastructure works and the
production of treated water.
Terms of Reference for Value for Money Review of Rural Water Programme
One of the first issues to be considered in carrying out a Review of the Rural Water
Programme is to determine the period of the Review. Five natural evaluation periods present
themselves;
1989-2006 – Group Water Schemes programme since last Review in 1989
1997-2006 – Group Water Schemes programme since devolution to local authorities
1998-2006 – Group Water Schemes programme since the start of the Rural Water Programme
2000-2006- Rural Water Programme during period of the NDP 2000-‘06
2003-’06 – Rural Water Programme during the period of the Action Plan for Rural Drinking
Water Quality 2003-‘06
17
It was decided to opt for the final evaluation period as it reflects the outcome of the 2002 ECJ
ruling, which has driven policy implementation since then. The Review will not include the
Small Public Water and Sewerage Scheme and Well Grant elements of the Rural Water
Programme as their objectives are not directly related to the private Group Water Schemes
sector. The Terms of Reference for this Review (see Page 5) are in line with the
recommended Department of Finance template.
Capital Expenditure Measures under Rural Water Action Plan 2003-‘06
The table below shows expenditure on each of the capital measures during the period of the
Action Plan for Rural Drinking Water Quality 2003-‘06. An explanation of each of the
spending measures and the grant conditions are also provided below. It should be pointed out
that the €6,476 (IR£5,100 approx. i.e. 85% of £6,000) per house grant limits referred to below
were decided by the Minister for the Environment, Heritage and Local Government in March
2000. However, there does not appear to be any documented information available within the
Department as to how this grant level was determined, apart from Ministerial instruction.
Table 1.2 Annual Expenditure on Capital measures under the Rural Water Programme
Expenditure on Capital
Measures (€ million)
Design Build Operate (DBO)
DBO Advance Work
LA Takeover
2003
2004
2005
2006
Total
8.723
21.194
33.812
31.568
95.297
-
16.874
18.464
35.338
9.467
8.91
10.884
16.924
46.185
Upgrade of GWS networks
30.352
20.323
25.738
28.996
105.409
Connect to the Public Main
-
5.367
6.751
3.895
16.013
55.794
94.059
99.847
298.242
Total
48.542
Source: Department of the Environment, Heritage and Local Government
DBO Treatment Plants
The Department funds 100% of the cost of the mechanical and electrical works component of
water treatment plants. The civil works contract, which includes the plant building, access
roads, reservoirs and rising mains is 85% funded by the Department with a 15% contribution
18
from the Group Scheme. The total Departmental grant cannot exceed €6,476 per the number
of houses served by the Group Scheme (Circular L11/04).
The Group Scheme must pay the operation and maintenance costs (O&M) of the DBO water
treatment plant and the pipe network distribution system but domestic householders each
receive an annual operating subsidy from the Department of €196.81 for each house in the
Scheme. This high rate of subsidy is paid in recognition of the fact that the Group Schemes
are paying a professional DBO operator to treat their water. DBO plants are usually procured
as bundles with several DBO treatment plants in a County being procured as part of a single
contract to achieve economies of scale and attract more competitive bids from large
consortiums. In some cases, it has been decided to use interconnecting pipes to connect a
number of Group Schemes to the same treatment plant as a sub-bundle to achieve further cost
economies. In the case of a DBO sub-bundle, any interconnector pipes linking several Group
Schemes to one treatment plant, are 100% funded by the Department within the overall
€6,476 per house grant limit.
DBO Advance Works
In some Group Schemes, it has been decided to proceed with certain elements of the civil
works contract ahead of the DBO contract due to delays in finalising the DBO bundle. The
cost of these Advance DBO works is also contained within the Department’s grant limit of
€6,476 per house for the overall DBO project.
Non-DBO Treatment Plant
This is the water quality upgrade that has been identified for 21 of the 729 schemes (3%). It
encompasses all water quality upgrade solutions involving the installation of a stand alone
treatment facility, not procured by way of a DBO contract. In some cases, it simply involved
upgrades to existing treatment infrastructure. It is currently funded out of the network upgrade
capital measure in Table 1.2 above. The operational and maintenance costs of the treatment
infrastructure and the pipe network distribution system are paid for by the Group Scheme but
they receive a domestic subsidy towards it from the Department of €101.58 for each house in
the Scheme. Group Schemes can claim the higher €196.81 rate where the water
19
disinfection/treatment plant is operated and maintained by a contractor by way of a bona fide
Operational and Maintenance Contract.
Local Authority Takeover of Group Schemes
All costs incurred by the local authority in completely taking over the Group Scheme
including connection to the public mains and upgrading or replacement of existing pipe
networks, is recoupable from the Department. There is no spending limit specified by the
Department although this is under review. Group Scheme domestic households receive no
subsidy post-takeover as they have been fully absorbed into the public water system so pay no
direct water charges. The Department has made a conscious decision not to require a 15%
capital contribution from Group Schemes under this solution to encourage Group Schemes to
accept complete takeover by local authorities. This is the best guarantee of ensuring that
Group Scheme consumers receive high quality water as the water is treated and the pipe
networks maintained by professional local authority staff.
Connection to the Public Mains (CTPM)
Some Group Schemes have accepted connection to the public mains (CTPM) but want to
remain independent of the local authorities and maintain their own pipe distribution network
privately. 85% of the costs incurred in connecting the Scheme to the public mains is
recoupable with a 15% Group Scheme contribution. The overall costs cannot exceed €6,476
per the number of houses served by the Group Scheme. Prior to 2004, the costs involved in
connecting Schemes to the public mains were paid under the network upgrade measure. The
Group Scheme funds the operation and maintenance (O&M) costs of the pipe network
distribution system but domestic householders receive an annual operational subsidy from the
Department of €50.79 per house in the Scheme. Group Schemes connected to the public
mains, generally referred to as Public Group Schemes, receive a lower rate of subsidy as they
do not have to pay for water treatment costs. They do have to pay local authorities for their
water supply but the Department recommends that each domestic household should receive
50,000 gallons per year from the Council for free. This means in practice that only nondomestic water users on Public Group Schemes pay local authority water charges in the same
way as other commercial operations on the public water system.
20
Disinfection/Sterilisation
Group Schemes make a 15% contribution towards this treatment solution with the remaining
85% funded by the Department. The maximum grant aid cannot exceed €6,476 per the
number of houses served by the Group Scheme. This water quality upgrade solution is funded
out of the Network Upgrade measure. In 2007, the Disinfection/Sterilisation solution received
a separate annual allocation of €1.07 million for the first time. The operational and
maintenance costs of the treatment infrastructure and the pipe network distribution system are
paid for by the Group Scheme but they receive a domestic subsidy towards it from the
Department of €101.58 for each house in the Scheme. Group Schemes can claim the higher
€196.81 rate where the water disinfection/treatment plant is operated and maintained by a
contractor by way of a bona fide Operational and Maintenance Contract.
Capital Expenditure on Non-Water Quality Upgrade Solutions
Network Upgrades
This was the original grant measure for the Group Water Schemes programme to fund the
construction and upgrade of the pipe network system connecting Group Scheme households
to their water source. Departmental funding cannot exceed €6,476 per the number of houses
served by the Group Scheme and Scheme members must make a 15% capital contribution
towards the network upgrade. A second network upgrade grant can only be paid to Group
Water Schemes connecting to a DBO water treatment plant. Network upgrades for the other
treatment solutions must not exceed the overall €6,476 grant limit for their water quality
upgrade solution. Councils are asked to only prioritise critical mains upgrades, which are a
necessary part of reducing water leakage on Schemes undergoing water quality upgrade
works. It is notable that this was the second highest spending capital measure (after the DBO
measures) with expenditure of €105 million between 2003-’06. It must be remembered
though that Non-DBO, Disinfection/Sterilisation and New Schemes works [and CTPM works
before 2004] were also funded under this spending measure.
New Schemes
Since 2006, funding for new Group Scheme pipe networks and extensions to existing Group
Schemes have been allocated under a separate New Schemes measure. The allocation for
21
2006 was €9.583 million and it was €12 million for 2007. Prior to 2006, New Schemes were
funded under the Network Upgrades measure. However, New Schemes outturn expenditure
for 2006 was still recorded under the 2006 Network Upgrades outturn total of €29 million
(see Table 1.2 above) so there is no separate outturn figure available for New Schemes. New
Group Scheme applicants must make a 15% contribution towards the capital cost and the
Department funds the remaining 85% up to a limit of €6,476 per house.
This is a particularly important measure as it adds to the number of Group Schemes that the
State is responsible for funding. The Department is unofficially encouraging County Councils
to only fund new Group Schemes, which are connected to the public mains as new Group
Schemes with private water sources will only potentially add to the list of deficient Group
Water Schemes, which may require future water quality upgrading works. However, the
Department has never issued formal instructions to Councils to stop authorising applications
for new Private Group Schemes in their area. Fitzpatrick Associates predicts that the recent
guidelines on rural housing will lead to an increase in demand for water in rural areas and
increased demand for connections to Group Water Schemes. It will also increase the potential
risk to groundwater (2005, p.45). The issue of New Group Schemes and their potential future
funding implications for the State will be discussed in Chapter 4 of this Review.
Current Expenditure – Annual Domestic Subsidy
Annual expenditure under the domestic household subsidy scheme is set out in Table 1.3
below. Annual expenditure has increased by approx. 50% between 2003 and 2006.
Table 1.3 - Expenditure on Domestic Subsidy 2003-‘06
Expenditure (€ million)
2003
2004
2005
2006
Domestic Household Subsidy
5.305
5.276
7.141
7.957
Source: Department of the Environment, Heritage and Local Government
The number of Group Schemes in receipt of the subsidy under the different categories is
outlined in Table 1.4 below. The subsidy is a relatively small element of annual expenditure
22
under the Rural Water Programme. However, it is an ongoing annual cost to the taxpayer and
as such it will be reviewed in Chapter 4.
Table 1.4 - Number of Group Water Scheme claims per subsidy category
No. of Group Water Schemes claiming
Subsidy
Public GWS Subsidy (€50.79 per house
max.)
Private DBO Subsidy (€196.81 per
house max.)
Private Non-DBO subsidy (€101.58 per
house max.)
Total No. of Group Schemes
2003
2004
2005
2006
128
130
111
82
23
24
27
33
520
518
467
316
671
672
605
431
Source: Q. 26. Compiled from Local Authority Questionnaire Returns 2007
Other Current Expenditure
The Department funds a Rural Water Liaison Officer post in most County Councils at a cost
of approx. €35,553 per Council per year. The Department also contributes towards a portion
of Councils’ annual administration costs under the Rural Water Programme and paid out a
total of €2 million for administration costs in 2006. It is not proposed to review these
expenditure elements as they also relate to administration and liaison work carried out by
Councils on Rural Water Programme measures, outside this Review’s terms of reference.
An annual grant of €500,000 is also paid by the Department to support the full time activities
of the National Federation of Group Water Schemes (NFGWS). The Federation makes a
strong case for retention of their annual subvention due to their active participation in
delivering implementation of the Action Plan, in partnership with the Department (See
NFGWS submission -Appendix 3). Given the Federation’s crucial and active role as the
recognised representatives of the Group Schemes’ sector in Ireland, it is not proposed to
review the payment of their annual grant at this sensitive time in the delivery of water quality
upgrade works under the Rural Water Programme.
23
Issue of Private Group Schemes
It should be emphasised at this point that the major current concern of the European
Commission is the sub-standard level of water quality in privately sourced Group Water
Schemes. The Environmental Protection Agency’s (EPA) Drinking Water Quality Reports
have highlighted problems with microbiological contamination and the presence of E.coli in
these Schemes over many years. The Department has accordingly instructed local authorities
to progress water quality upgrades on privately sourced Group Schemes as a matter of
priority. Works on publicly sourced Group Schemes should be given a lower priority.
Therefore, the main focus of this Review will be on the efficiency and effectiveness with
which local authorities have implemented the five water quality upgrade solutions for the 584
privately sourced Group Schemes.
Issues to consider in a VFM Review of the Group Water sector
It is important to first get an overview of each stage of the water treatment cycle and its
consequent cost implications. The diagram below provides a very basic representation of a
water treatment and distribution system for a Group Water Scheme. Raw water is abstracted
from either a surface water (river or lake) or groundwater source and is pumped to a water
treatment plant for treatment. The treated water is then usually pumped to a water storage
facility/reservoir. As the water is required, it is then pumped into the pipe network and
distributed to the homes of water consumers.
Abstraction
from Water
Source
Water
Treatment
Plant
Water
Storage/
Reservoir
Water
Distribution
Network
House
Tap 1
House
Tap 2
Farm
Tap
24
The table below illustrates the respective responsibilities of Group Water Schemes (GWS),
DBO providers and the local authorities (LAs) for each stage in the water treatment cycle for
each of the five water quality upgrade solutions for Group Water Schemes.
Water Quality Upgrade
Water
Water
Water
Water
Measures
Source
Abstraction
Treatment
Distribution
DBO treatment plant
GWS
DBO provider
DBO
GWS
provider
Non-DBO treatment
GWS
GWS
GWS
GWS
Disinfection/Sterilisation
GWS
GWS
GWS
GWS
Connect to public main
LA
LA
LA
GWS
LA Takeover
LA
LA
LA
LA
There are a number of cost issues relating to each stage of the process, which are outlined
below.
Water Source and abstraction
The quality of the raw untreated water at source will be a major determinant of the cost of
treating it. Waters are generally classified as Grade A1, A2 and A3 for the purposes of
assessing treatment requirements. The European Commission and the Environmental
Protection Agency have particularly identified Group Water Schemes with private water
sources (i.e. not receiving their water from a public supply) as a major concern. The EPA has
reported that the quality of the raw source groundwater has declined in many places in recent
years due to pollution caused by inter alia certain farming practices and contamination by
faulty septic tanks in the area. This includes contaminants such as faecal coliforms and high
nitrate concentrations, which have been linked to methaemoglobinaemia [blue baby
syndrome] (Water Quality in Ireland 2006, p.21.). The issue of water source protection will be
addressed in Chapter 5 and the work of the National Pilot Source Protection project on the
Churchill-Oram Group Water Scheme will be considered. Another issue that also must be
borne in mind is the level of water abstraction from a water source as over abstraction from
water sources can have knock on environmental consequences for the ecosystem. Fitzpatrick
Associates (2005, p.vii) have noted that these environmental costs also need to be factored
25
into the process. There are also specific environmental issues in relation to water quality
upgrade works in Special Areas of Conservation.
Water Treatment
As already stated, the nature of the source water quality will be a major determinant of
treatment costs. There will also be pumping costs involved in transferring the water from its
abstraction point. In a limited number of cases where the source water is of particularly good
quality, it may be possible to treat it using basic disinfection and sterilisation. This is a very
cost effective solution but there are concerns as to its sustainability and also the possible
health risk caused by using chlorination (carcinogenic THMs). These issues will be teased out
in the section on the disinfection and sterilisation upgrade solution in Chapter 4. In most
cases, a water treatment facility will be required to treat the water. This usually involves two
core work contracts, a civil works contract and a mechanical and electrical contract. The civil
works contract usually involves the construction of the treatment plant building, a water
storage reservoir and necessary rising mains to pipe the water between the source, treatment
plant, reservoir and the start of the distribution network. The Mechanical and Electrical
contract (commonly referred to as the Mec& Elec contract) involves the installation of the
water treatment technology as well as any pumps needed to transfer the water. The size of the
water treatment plant and its plant capacity will be determined by the population needs of the
plant as well as the quantity of source water available.
The procurement of a water treatment plant can generally be done in three ways, traditional,
design build or design build operate. Traditional procurement involves separate procurement
of contracts to design and build the plant. Design Build involves a single contract for the
design and build of a treatment plant. Design, Build, Operate (DBO) involves procuring a
single contractor to design, build and operate a treatment plant usually over a 20 year period.
The DBO procurement approach has been favoured in recent years as it is regarded as
providing best value for money particularly as the whole life cost of operating and
maintaining the plant are included in the contract cost along with the initial capital cost of
construction.
26
Water Distribution Network
After the water is treated, it is usually stored in a reservoir in order to ensure that there is
available water supply to meet various demand levels at different times of the day. Reservoirs
are often located on a high level so that water can flow down to recipient households using
gravity. If households are located at a high level or are distant from the reservoir, there may
be additional costs involved in pumping water to those houses. Because of the dispersed
nature of rural populations, the pipe networks are generally far longer than those serving
individual households in urban areas. Apart from the cost of additional piping, this also adds
to the problem of Unaccounted for Water or UFW as water leaks out of the pipe network
including at pipe joints. This partially explains why UFW is so high in rural areas. Longer
pipe networks also mean increased pipe network maintenance costs. Poorly maintained pipes
can lead to leaks, which increases the level of UFW in the pipe network. Increased UFW
reduces the level of treated water available to households and can potentially result in water
shortages. The major cause of UFW is overuse of water by certain consumers particularly as
most rural water supply usage is not metered.
Water providers generally have two choices either, to try and reduce UFW through pipe
network upgrades or alternatively to increase plant capacity. Leakage control studies of rural
water usage in Mayo and Galway have shown that active leakage control policies, including
the installation of water meters on all connections, are a very cost effective means of reducing
water demand and avoid the need for unnecessary treatment capacity increases (Ryan Hanley,
2004 & 2005). Poorly maintained and sub-standard pipe networks can also create another
serious problem –recontamination of treated water in the pipes. This problem can be
addressed by ensuring that there is sufficient residual chlorine in the water post treatment to
ensure that the water is not re-infected by contaminants within the pipe. It is important that the
quality of the water flowing into the last household at the end of the pipe network is regularly
checked to ensure that it contains sufficient chlorine levels.
It is important to note that the DBO operator does not have any role in the maintenance of the
pipe network and their responsibility ends when the treated water is released into the Group
Scheme network. The National Federation of Group Water Schemes and the Water Services
National Training Group have established a Performance Management System (PMS) for
27
DBOs and run training courses for Group Water Schemes in the management of pipe
networks. This has traditionally been done on a voluntary basis by individual Group Schemes,
however, there is an increasing recognition by the National Federation (Cavan Annual
Conference – September 2006) and practitioners in the field that there is a need for
professional paid staff to carry out this operational and management role.
Non-Domestic Users and the Water Pricing Framework
As can be seen from the above diagram (p.24.), treated water is also used for non-domestic
purposes particularly for farming purposes. Current Government policy is that the cost of
treating and supplying water for non-domestic purposes must be recovered from those users
in accordance with the Water Pricing Framework. This includes the volumetric costs of
supplying the water as well as the marginal capital cost of providing the treatment
infrastructure to meet non-domestic demand. Non-domestic water charges are a particularly
contentious issue in connecting Group Schemes to the public mains. Farmers originally built
many Group Water Schemes, on a voluntary basis, to provide piped water for their farming
needs. They own their group schemes and in some cases see little need for water treatment.
The application of the Water Pricing Framework will be considered during the course of this
study.
Benefits of a Rural Water Programme Value for Money Study
At its most basic, this value for money study is examining the effectiveness and efficiency of
the Rural Water Programme and assessing the rationale for its continuance. This includes an
assessment of the solution selection criteria and the implementation and cost efficiency of the
water treatment solution identified for each of the relevant Group Water Schemes (GWS).
More importantly has the identified solution resulted in the water coming out of household
taps meeting EU Drinking Water criteria? For example, does the construction of a state of the
art DBO water treatment plant guarantee that clean water will arrive in households through
the GWS distribution system? How is the quality of this drinking water monitored and
verified? On a similar theme, are there measures in place to protect the water quality source
from pollution to minimise water treatment costs? Was too little or too much treated water
produced to meet the needs of a GWS? How much water was lost in the distribution system as
UFW and is this cost carried by the taxpayer? As it is Government policy to recover non-
28
domestic water charges, did this occur in the GWS sector and was the marginal capital cost of
capital works recovered?
It could be argued that much of this is of little more than academic interest as the Irish
Government is committed to providing water treatment infrastructure without delay to avoid
incurring large fines for non-compliance with the Drinking Water Directive. However, the
729 Group Schemes may be the start of a longer term investment commitment in the Rural
Water Sector. Group Schemes with less than 50 persons but with one or more commercial
connections e.g. a pub, a B&B or even a dairy farm also fall within the criteria of the Drinking
Water Directive (EPA Circular DW 01/06). There are several hundred additional Group
Water Schemes with <50 persons and it is estimated that a considerable proportion of these
may have such a commercial connection. There is also a steady demand for government
funding to build new Group Water Schemes. At the same time, the Water Services Act 2007
provides a statutorily enforceable licensing system for the first time to ensure that Group
Water Schemes meet basis water quality standards. It is, therefore, an opportune time to
reassess the rationale for the Rural Water Programme and question whether the current
approaches provide best value for money and achieve necessary water quality outcomes.
29
Chapter 2
Literature Review - Rural Water Programme
30
Rural Water Programme Literature Review
Introduction
The Rural Water Programme has evolved considerably since its original inception in the early
1960s as the Group Schemes Programme and this is reflected in the available literature. This
chapter is divided into three sections. The first deals with background literature, which is
important to gain an understanding of how the modern Group Water Schemes Programme has
evolved. It is also a vital aid to putting many of the issues that will be encountered in this
Value for Money Review in context, particularly as some issues will be unique to the Group
Schemes’ sector. The second part of this review looks at comparative European literature to
assess how other EU member states, with private water supplies, have implemented the
Drinking Water Directive. This is important in identifying possible alternative policy
approaches for Ireland. Finally and most importantly, the third part of this literature review
examines previous analytical studies of the Irish water services sector. This is an essential aid
to identifying issues of efficiency and effectiveness in the Irish water sector and possible
methodological approaches for the Value for Money Review of the Rural Water Programme.
Background Literature
Historical Context
A useful starting point for understanding the background to the Group Schemes’ sector in
Ireland is Professor Mary E Daly’s “The Buffer State: The Historical Roots of the Department
of the Environment” (IPA, 1997), which draws heavily on Departmental archives. According
to the 1956 Census, only 3% of rural households, had access to public water supplies. By
contrast, the ESB had connected over 50% of rural households (163,000 consumers) between
1947 and 1956, under the rural electrification programme (p.483.).
In 1959, the Government approved a £35 million ten year programme, submitted by the then
Department of Local Government to provide running water in rural areas. This programme
would be funded through a combination of central Government grants and local authority
rates. The Department of Local Government initiated a national publicity campaign on the
31
merits of piped water but encountered strong opposition from the National Farmers’
Association (NFA), the precursor to the Irish Farmers’ Association (IFA). The NFA “objected
to the additional cost imposed on [local authority] rates” as “most larger farmers, who
dominated the NFA, already had piped water in their homes and saw no benefits from the
scheme” for them personally (p.484). The then Minister for Local Government’s [Neill
Blaney) main opponent in cabinet was the Minister for Agriculture (Paddy Smith), who
supported the NFA position. “In January 1962, Smith informed Blaney that there was
growing opposition among rural organisations and farming interests to any extension of
regional water schemes….He argued that individual or group schemes using ground water
were preferable” on cost grounds (ibid, p.485.).
Minister Blaney rejected the argument that regional water supply schemes were too
expensive. However, as a compromise, “the 1962 Government (Sanitary Services) Act
provided a new scale of grants and loans for group and private schemes in an effort to silence
those who claimed that the government was biased in favour of elaborate regional schemes”
(p.487.). The Department of Agriculture relinquished control of its own rural water grants
scheme to Local Government and the modern Group Schemes Programme, as we know it
began to evolve “This new emphasis on group water schemes continued for the remainder of
the 1960s …and by 1964 promotional activities had as their main theme…the encouragement
of private enterprise, particularly by co-operative group schemes” (p.487.). The regional
water supply programme was cut back in 1965/66 to give priority to housing and never
regained the momentum lost ‘because of ratepayer/farmer resistance” (p.488.). By 1969, the
primary object was to improve water and sewerage facilities in built-up areas. Rural needs
would continue to be met as far as possible, with local authorities providing head works and
trunk mains, which would be linked to co-operative group schemes (ibid).
“The Buffer State” (1997) provides enlightenment into how the modern Rural Water
Programme, based on a Group Schemes structure, evolved. It also shows that there was a
period, when extensive regional public water supply schemes were being promoted by central
government but this was opposed by big farming and other ratepayer interests, in favour of
Group Water Schemes. It certainly refutes any argument that central government ignored the
32
needs or will of rural Ireland, albeit the NFA big farmers, in determining how water
infrastructure should be provided to rural communities.
Evolution of the Group Scheme Programme
While the scope of this Review is the 2003-’06 Action Plan period, it is important to track
how the Scheme has developed in recent decades. A useful starting point, in this regard, was
the last comprehensive Review of the Group Water Schemes Programme published by the
Department of Finance in May 1989. The terms of reference of the Review were broadly
similar to this Value for Money Review in that it sought to analyse the efficiency and
effectiveness of the Scheme in meeting its objectives. The objective of the Scheme at the
time, however, was to ‘provide water of adequate quality to as many houses as is feasible’
(Department of Finance 1989, p.i). There was an equal focus on water supply and water
quality at the time. The report concluded that “it would appear that the Group Water Schemes
Programme is a cost effective means of providing water supplies in rural areas” (p.21.). It
must be remembered, however, that Group Scheme grants at that time were mainly for pipe
networks rather than for water treatment infrastructure.
At that stage, water quality had not taken priority to the same extent as it has today. The
Review did, however, made some preliminary observations in relation to initial water quality
test result data, which had been collected in accordance with the 1988 EC Regulations on
water quality. “First indications from these tests are that there are bacteriological problems
with water quality in a number of group water schemes…Based on the EC regulations, there
must be some question as to the success of the Group Water Schemes Programme in
providing water of an acceptable quality for human consumption” (p.17.).
In considering the pro and cons of Group Schemes versus public water supply schemes, the
Review recognised that community initiative expedited the development of Group Schemes
far quicker than the development of public schemes. It also recognised that Group Schemes
could be delivered and operated at a lower cost due to the voluntary efforts of its members.
However, it also concluded that it was difficult for local authorities to enforce water quality
regulations on privately owned group schemes and that water was not being properly treated
or treated at all in many Group Schemes (p.30.). “The small size of most groups makes the
33
provision of more sophisticated water treatment facilities uneconomical”(p.31.) “In some
cases also, resistance to water rates may result in them refusing to accept better quality
supplies from public sources” (ibid). The Review recognised that there was no easy solution
to Group Schemes’ resistance to paying for public water supplies but “that there was a need to
take a flexible pragmatic approach in encouraging groups to accept greater local authority
involvement in helping to improve water quality in their schemes” (p.53.). It was
recommended, however, that additional conditions in relation to water quality standards, be
made a requirement for payment of grants for new Group Schemes to try and avoid future
water quality problems (p.51).
In 1989, Group Schemes Programme grants were centrally administered and scheme
proposals technically assessed by the Department of the Environment with minimal
involvement by the relevant local authorities. The Review considered the possibility of
devolving the administrative and/or the technical functions from the Department to local
authorities. It recognised the benefits of accumulating local knowledge in devolving the
Programme to local authorities (p.39.) but also warned of the dangers of Councils diverting
funds from group schemes to public schemes (p.38.). There were also concerns that interest in
the Group Schemes’ sector could differ between local authorities and that there could be a
reduced interest in cost control with funds coming directly from the Department via the local
authorities (p.38.) The Review recommended either the retention of the existing centralised
system or the devolution of the technical inspection role only although recognised that this
was a matter for the Minister for the Environment to decide (p.45.). The Minister for the
Environment subsequently fully devolved the Group Schemes Programme to local authorities
in 1997. The 1989 Review concluded overall that the Rural Water Programme constituted
value for money and should continue, albeit with a greater proportion of its expenditure on
water quality investment (p.61-63.).
The 1989 Review provides an early insight into many of the issues that now dominate the
sector and, in particular, the water quality issue. While acknowledging that the Group Scheme
model was cost effective in the past, it recognised that in future water treatment costs could
become a major issue. It also predicted difficulties in persuading privately owned Group
Schemes to adopt water quality measures and particularly being connected to the public mains
34
because of local authority water charges. This was somewhat prescient of the difficulties
currently involved in implementing the two treatment solutions involving connection to the
public mains, which will be discussed in Chapter 4. The recommendation that greater
conditionality be placed on new Group Schemes in order to avoid future costly water quality
problems has even greater relevance today and will be considered when reviewing the New
Schemes element of the current Programme.
Action Plan for Rural Drinking Water Quality 2003-2006
In 2003, the National Rural Water Monitoring Committee (NRWMC) launched the Action
Plan for Rural Drinking Water Quality 2003-2006 “with the objective of bringing the quality
of rural water supplies into compliance with the Drinking Water Regulations 2000, and to
achieve this within the shortest possible timeframe (NRWMC 2003, p.3.). The Action Plan
recognised that there were water quality problems with some publicly sourced Group
Schemes, which should be addressed with improved operation and maintenance (O&M) of the
Group Scheme network, including ensuring that there was adequate residual chlorine in the
water supply entering the pipe network, to avoid re-infection (ibid, p.5.). The Action Plan,
however, identified Group Schemes with private water source as being the biggest compliance
concern. The Action Plan recommended that there be a focused programme of capital
investment over the 2003-06 period in order to bring sub-standard privately sourced schemes
into compliance with the Drinking Water Directive. It recognised that it was unrealistic to aim
for full compliance by the 1 January 2004 deadline but did recommend that all actions
required for compliance be “fully in place within the timeframe of the NDP (i.e. end 2006)”.
The Action Plan “reflects that timeframe” (ibid, p.9). The Action Plan acknowledges the €644
million available under the NDP 2000-2006 for delivery of the Rural Water Programme (ibid,
p.9). It proceeds to identify the various water quality upgrade solutions involving either
connection to the public mains or stand alone treatment i.e. DBOs and
Disinfection/Sterilisation. It also recommended “that investment in network renewal should
be the priority once the source quality issue has been dealt with” (ibid, p.11).
While the implementation of capital works being undertaken under this Action Plan are the
main focus of this Value for Money (VFM) Review, it is useful to note other issues raised by
the NRWMC in the Action Plan. The NRWMC emphasised the important of putting in place
35
effective Project Management Systems, particularly for large-scale bundled DBO projects.
This should include the setting up of Steering Committees for each DBO bundle to oversee
the project with a project manager i.e. Client Representative reporting jointly to the Group
Schemes and local authority during the Design Build phase of the project. There should also
be a Rural Water Liaison Officer in every local authority working full-time on progressing the
implementation of the County’s Rural Water Strategic Plan. Finally, there should be a
National Projects Manager overseeing the implementation of the DBO Bundles’ projects
nationally and reporting to the NRWMC (ibid, p.11-12.). The Action Plan also recognised the
need for capacity building to ensure that Group Scheme personnel were adequately trained to
administer and manage their new responsibilities to get the full benefit from capital
investment (ibid p.12.) The Department adopted all of these measures.
The Action Plan also considered the two important issues of source protection and water
conservation. The Plan states that “the task of supplying quality water should not rely solely
on water treatment strategies” (p.13.). There needs to be a greater focus placed on source
protection. Therefore, the NRWMC proposed “to develop a model of best practice in the
monitoring and protection of catchment areas” (p.13.). This project has proceeded as the
National Source Protection Pilot Project, which will be discussed in Chapter 5 of this Review.
The Action Plan also recognised the growing issue of water conservation and the costs of
treating and pumping treated water instead of raw water to households. “In many instances, it
is far more cost effective to conserve water by way of an active programme of leak detection
and eradication, as opposed to upsizing the capacity of the plant or commissioning additional
sources” (p.13.). The NRWMC recommended the installation of bulk and district metering on
all DBO projects and consideration of usage of rainwater collection technologies for
agricultural and non-domestic Group Water Scheme consumers (p.14.).
Towards Quality Water: A review of the work of the NRWMC and implementation of
the Action Plan 2003-2006
This Review was published in early 2005 at the mid point of the Rural Water Plan and also to
coincide with the end of the NRWMC’s second 3 year term. The Review recalled that the
numbers of sub-standard privately sourced Group Water Schemes and the short timeframe for
36
bringing them into compliance with the Drinking Water Directive “raised obvious questions
as to the feasibility and (cost effectiveness) of resolving non-compliant schemes one at a
time” (2005,p.4.). NRWMC members visited a number of small communities in Brittany,
France in 2000 to see how they dealt with water and wastewater treatment. Although the
Brittany plants were under State control, the small plant treatment technologies used in these
rural areas were very relevant to Ireland.
“The potential benefits of adopting a design, build, operate (DBO) approach and of bundling
smaller schemes as part of a larger contract were apparent…. Market soundings at home and
abroad indicated strong interest by major DBO consortia, provided projects had critical
mass. Given the relatively small scale of group water schemes , critical mass could only be
achieved if a number of schemes were to be bundled as part of a single contract” (2005, p.4.)
The Review goes on to explain how the Action Plan for Rural Drinking Water Quality 20032006 and its implementation timeframe was driven by developments at the European level
and particularly by the 2002 ECJ ruling. The Action Plan was accepted by the European
Commission “as the nucleus of a coherent strategy” (p.5). The Review examines
implementation at that point under the Action Plan. Significantly, it noted that “local
authorities have identified 191 schemes as requiring disinfection only. The NRWMC
questions the sustainability of this approach and recommends that each Council review the
quality of raw water (based on source monitoring) and look again at the appropriateness of
this solution” (p.8.). The Review also referred to successive EPA reports, which showed that
local authority testing of Group Water Schemes was inadequate in many cases and needed to
be improved. It also referred to the fact that the testing parameters were broadened in 2003 to
address concerns of Trihalomethane (THMs) contamination, due to incorrect water
chlorination (p.10-11.) This is a possible risk factor for the Disinfection/Sterilisation
treatment solution.
The 2003 Action Plan and its 2005 Review clearly illustrate the complexities involved in
tackling water quality problems in a Group Scheme sector, where there is no neat ‘one size
fits all’ solution. Group Schemes, with private water sources, have clearly been identified as
being the core problem. The need to comply with the Drinking Water Directive and avoid
37
ECJ fines meant that a major infrastructural programme needed to be carried out within a
short timeframe. This also required a project management structure to be put in place at both
central and local government level to ensure implementation and control costs. The small
scale of many Group Schemes raised serious cost effectiveness issues and the DBO Bundle
procurement strategy evolved based on an examination of the Brittany approach to providing
small public water treatment infrastructure to rural communities. This practice of procuring a
number of DBO plants together created a large enough contract to attract interest from
international consortia and thus encouraged competitive market bids for the contracts. The
Action Plan and its 2005 Review also raise important points in relation to the need for greater
water conservation and pipe network renewal investment, as well as source protection, in the
Group Schemes sectors. The issue of water quality monitoring, the THM risk factor and the
questions in relation to the sustainability of the Disinfection/Sterilisation treatment solution
also need to be considered further in this Report. The Action Plan also reminds us that Group
Schemes are privately operated voluntary organisations and the critical success factor of
“ongoing co-operation and partnership between the key stakeholders to the RWP” is perhaps
the most important in implementing the objectives of the Action Plan (2003, p.14.).
National Federation of Group Water Schemes -Strategic Plan 2006-2008
The National Federation for Group Water Schemes (NFGWS), usually referred to as the
Federation, was founded in 1997 as an umbrella representative body for the Group Schemes
sector. In recognition of the Federation’s role, it has been represented on the National Rural
Water Monitoring Committee since its inauguration in 1998. It is important, therefore, to
consider the Federation’s perspective, particularly in relation to the future direction of the
Rural Water Programme.
In its Strategic Plan 2006-’08, it states that
“we want to get to the point where the Federation effectively services the needs of communityowned group water schemes run to a professional standard. We want to finally resolve the
issue of deficient water quality and move beyond the present focus on end-of-pipe solutions to
providing sustainable quality water supplies through an increasing emphasis on source
protection and water conservation”.(2006, p.1.)
38
This is a very significant statement as it demonstrates that the Federation realise that source
protection and water conservation provide a more sustainable future for the Group Schemes’
sector than just water treatment solutions alone. The Federation see the reduction of UFW and
the promotion of wider strategies arising from the completion of the National Source
Protection Pilot Project as tangible ways of meeting these objectives (2006, p.5.).
The Federation also see an urgent need to ensure that all Group Schemes serving less than 15
houses but with a public or commercial function are identified as they must also comply with
the Drinking Water Regulations. Cost effective treatment solutions must be identified for
these schemes (2006, p.2.). This indicates that the Federation believe that there are several
small Group Schemes requiring upgrading yet to be identified, which will have cost
implications for the State. On a similar theme, the Federation recognises that many smaller
Group Schemes will not be financially viable in the future, especially where water quality
upgrades are required. For those schemes, amalgamation with neighbouring schemes or
connection to the public mains may be the only option (2006, p.5.). The issue of smaller
schemes will be an issue, which will be examined later on in this Report in the context of new
schemes and alternative policy approaches. Naturally as the representative body for the Group
Schemes’ sector, the Federation want to see the continuation of operational costs subsidy for
domestic consumers on Group Schemes. Their objective is “to defend current subsidy
arrangements and to pursue enhanced grant aid towards the operational and maintenance costs
of group schemes” (p.5, 2006).
The Federation’s views on the future of the operational subsidy for domestic households are
characteristic of any proactive interest group. Their views on water conservation, source
protection and the viability of smaller Group Schemes do, however, demonstrate a
considerable level of enlightened self-interest, which sets out a sustainable blueprint for the
future of the Group Schemes’ sector. It has generally been acknowledged that the Federation
have played a vital partnership role in assisting the Department and local authorities in
implementing water quality upgrades in the Group Schemes’ sector so it is important that
their views are considered in future policymaking in that sector.
39
Comparative International Studies
European Perspectives
The need for Ireland’s Group Scheme sector to comply with the Drinking Water Directive
raises the inevitable question of what other EU member states are doing about bringing
private water supplies in their jurisdictions into compliance with the Drinking Water
Directive. The answer to this in many cases is unclear. An informal group comprising
officials from EU member states with responsibility for implementing the current and
previous Drinking Water Directives was formed in 1995. This group known as the European
Network of Drinking Water Regulators (ENDWARE) meets twice a year and this forum
“provides an informal route of communications with the Commission” (www.europa.eu). An
official from the Environmental Protection Agency (EPA) currently participates in this
informal network. In 2005, the ENDWARE members participated in a survey by the Webbased European Knowledge Network on Water (WEKNOW) and a report entitled “Small
Systems Large Problems: A European inventory of small water systems and associated
problems” was subsequently published online (Hulsman, June 2005 http://www.weknowwaternetwork.com). The report includes a disclaimer that the data collected was not officially
approved by respective national Governments and that it was possible that some of the
information contained therein is not entirely correct (p.1.).
The report estimates that “at least one in ten Europeans (40 to 50 million people) receives
their daily drinking water from small and very small supplies, including private wells. There
is an urgent lack of reliable information on the number of such supplies and the number of
people served by such supplies” (p.7.). In this report, small supplies are defined as supplies
serving between 50 and 5,000 people, while very small supplies are
defined as serving less than 50 persons. Small supplies are required to comply with the
Drinking Water Directive, while very small supplies are exempt unless they are connected to
a premises serving a commercial or public function (p.9.). The report concludes that most EU
countries have little or no information on the number of small or very small supplies in their
country and this equally applies to both the 15 ‘old’ and 10 ‘new’ member states (p.7). “Most
countries report that they have no information on the number of small supplies that are used
for public or commercial activities” even though such supplies must comply with the
40
Drinking Water Directive (ibid). Microbiological contamination by faecal matter as indicated
by the presence of E.coli, coliforms and faecal streptococci “is by far the major problem with
water from small and very small supplies” (p.8.).
With regard to water treatment solutions, “connection to a centralised water supply (and
sewerage) system is by far the most popular remedial action countries see for problems
associated with small and very small supplies…very rarely nowadays decentralised water
treatment options are promoted for (very) small supplies” (p.8.). Finland, Romania and
Slovakia are listed as countries that have adopted a decentralised treatment approach. It would
appear, however, that Ireland’s extensive decentralised treatment plant programme approach
is not generally being adopted in other EU states. The report does comment, however that “it
is surprising that very little use is made of new decentralised treatment options that are
available nowadays”. It also comments that connection to a centralised water supply is not
always the most sustainable treatment solution for remote rural areas (p.31.). The report also
considered the issue of risk assessment/risk management of small water supplies. This is
already being adopted in many EU states, including Ireland, for public water supplies and
should also be considered for small supplies (p.35). In this context, the report refers to a then
recently published Scottish Executive consultation paper on private water supplies regulations
and grant aid.
Scottish Initiative
There were major developments in the regulation of the Scottish private water supplies sector
in 2006 to bring it into compliance with the 1998 Drinking Water Directive.
“Around 150,000 people in Scotland rely on a private water supply - any water supply not
provided by Scottish Water - for their drinking water. Instead of Scottish Water, the owner or
person who uses the supply is responsible for its maintenance. Supplies vary in size from
those that serve one household to those that serve hundreds of people…. The 2006
Regulations, which came into force on 3 July 2006, incorporate the latest advances to
improve drinking water quality including the use of risk assessments from 'source to tap' as
part of an effective drinking water surveillance programme…. Grants of up to £800 [€1,178
per premises] are available from your local authority provided certain qualifying conditions
are met.” (http://www.scotland.gov.uk/Topics/Environment/Water/pws/pws1).
41
The Scottish Executive have set up a dedicated website, with advice in relation to private
water supplies http://www.privatewatersupplies.gov.uk/. It expressly encourages private water
consumers sharing the same water source to make joint grant applications as “in the majority
of cases a joint approach is likely to provide the most effective long term solution to improve
your water quality”. A Private Water Users: Technical manual and consumers manual has
also been published on this website. The technical manual explains that “research carried out
for the Scottish Executive indicated that improvement costs are likely to vary greatly, largely
in the range of £125 - £2,500 per premises, but that the most important health benefits are
usually gained from installing ultra violet treatment and appropriate pre-filters. The £800
grant will meet or make a substantial contribution towards the costs faced by the majority of
users. There will be cases where the supply requires work, which exceeds this maximum and
in such cases, and subject to regulation 8(2) of the Grants Regulations, it will be the
responsibility of the eligible person to meet the additional costs”. (Technical manual Section
9, P.44.)
“During the autumn of 1996 and early 1997 a spate of outbreaks of E. coli O157 infections
resulted in the deaths of 20 elderly people in Scotland although not all outbreaks caused
deaths to occur. One of these non-fatal outbreaks was attributable to a private water supply at
Dunecht in North-East Scotland (Technical Manual 2006, Section 4, p.22.) This prompted a
focus on improved source protection guidance for water supplies. The 2006 Regulations
require that Scottish local authorities carry out risk assessments on all Type A private water
supplies i.e. all private water supplies required to comply with the Drinking Water Directive.
Risk assessments, seen as an essential element of an effective drinking water quality
surveillance and control programme, include
• identification of potential sources of contamination and how they can be controlled;
• validation of control measures employed to control hazards;
• implementation of a system for monitoring the control measures within the private supply;
• timely corrective actions to ensure that safe water is consistently supplied; and
• undertaking verification of drinking water quality to ensure that the recommendations
arising from the risk assessment are being implemented correctly and that quality standards
42
meet the prescribed concentrations or values set down in the 2006 regulations.” (Section 9,
p.21)
A risk assessment is a perquisite for receipt of remedial grant aid from the Scottish
Executive’s grant programme. This risk assessment approach complies with the latest
guidance from the World Health Organisation (WHO), which confirms that “the most
effective means of consistently ensuring the safety of a drinking water supply is through the
use of a comprehensive risk assessment and risk management approach that encompasses all
steps in water supply from catchment to consumer”.
At 618 pages, the Scottish Executive’s Private Water Supplies Technical Manual 2006
provides a rich source of best practice advice, which could be of potential benefit to policy
makers in the Irish group scheme sector.
When compared against our European counterparts, Ireland seems to have been quite
proactive in identifying and addressing the issue of water quality in private water supplies in
the Group Schemes’ sector. If nothing else, Ireland’s Environmental Protection Agency
(EPA) has reported annually on the water quality in these Group Schemes for many years
even if local authorities’ monitoring coverage is less than perfect. It would appear that Ireland
is, in many respects, a victim of its own transparency in highlighting the water quality
problems on its Group Schemes, thereby incurring the attention of the European Commission,
as watchdog of the Drinking Water Directive. The evidence suggests that other EU states have
not even properly identified their private water supplies. It is also interesting to note that the
European Commission and the Council of Ministers decided to include certain private water
supplies, within the terms of the Drinking Water Directive, with apparently little substantial
information about this sector.
That said, Ireland must meet its statutory obligations and the Scottish approach to making risk
assessments of private water supplies mandatory could point the way towards a more robust
approach to source selection and source protection, particularly in relation to grant aiding new
Group Schemes. This could avoid the need for expensive and economically unsustainable
treatment solutions for smaller Group Schemes in the future. It is also interesting to note that
Ireland’s investment in decentralised water treatment solutions is relatively unusual by
European standards but could be a more sustainable use of new small plant technologies.
43
Finally, Ireland’s grant aid limits of €6,476 per house for water quality upgrade solutions
appears to be quite generous, when compared against the Scottish Executive’s grant limit of
£800 (€1,178 per premises). That said, it must be borne in mind that the Scottish grant
programme only commenced in 2006 whereas Irish grant levels were only raised to their
current levels in 2000, based on experience of the real costs of upgrading group schemes’
water quality.
Comparative Analytical Literature
Comparative National Studies of the Irish Water Services Sector
Evaluation of Water Services Investment in the National Development Plan (NDP) and
Community Support Framework (CSF) for Ireland 2000-2006
Fitzpatrick Associates Economic Consultants carried out this evaluation in 2005 on behalf of
the Department of Finance’s NDP/CSF Evaluation Unit. This document is an invaluable
recent study of the overall national water investment programme. Because of its breadth, the
report only carried out a limited review of rural water p.26-28. (water quality in Group Water
Schemes) . However, the report’s findings do reflect on issues, which are relevant to this
study. The Review explained that due to the bespoke nature of many water treatment schemes
(p.5-6. & p.121.) serving widely varying population densities, it is not possible to set precise
benchmarks in terms of cost efficiency. “What may be good value in one place may be bad
value in another: depending on circumstances” (p.131.). The report does, however, look at the
benefits of new innovative procurement practices such as DB and DBO compared to
traditional procurement (p.94 & 140.). Such approaches reduces the incentive for local
authorities and consultants to understate final cost at scheme approval stage in the knowledge
that cost overruns on schemes in progress will be paid by central government in order to
ensure scheme completion.(p.iv). It also improves market competition in service delivery with
the effect of maximising plant efficiency and minimising costs over the lifetime of the project
(p.140.).
44
Fitzpatrick does, however, conclude that it will take several years to assess the value for
money (VFM) of DBO projects (p.96.). The report calculates the cost /per population
equivalent (pe) ratio of several completed water treatment schemes (p.121-128.) and
concluded that there is clear evidence that there are economies of scale to be had from larger
rather than smaller schemes. There are also administration and management economies of
scale to be had where smaller numbers of qualified staff can monitor and manage a number of
water facilities remotely. The report explains that while it is not cost efficient to have several
small water plants within the same water catchment areas, it is equally inefficient and
expensive to distribute water over large water networks in rural areas because of piping and
pumping costs (p.144.)
The Report also comments on the over emphasis on “big engineering” over more “mundane
activities” (p.138.) such as water conservation projects. The report expresses concern at the
lack of data available in relation to water consumption, production and leakage i.e.
Unaccounted for Water (UFW) because of the lack of metering (p.viii & ix). The report raises
the possibility that due to UFW, “Ireland could be as a country producing (i.e. extracting,
treating and sending down the pipe) about twice the level of water that would be reasonable to
assume we need”. (p.21.) The report also reminds readers of the environmental costs of water
treatment as water extraction places demands on primary water sources and water treatment
has energy costs (p.vii). It also predicts that the recent guidelines on rural housing will lead to
an increase in demand for water in rural areas and increase demand for connections to Group
Water Schemes. It will also increase the potential risk to groundwater (p.45.) Fitzpatrick
balances the advantages and disadvantages of the Group Water sector and concludes on
balance that the status quo should prevail for the moment at least as in its absence the public
sector would have to provide for the “existing customers” anyway (p.146)
Fitzpatrick Associates draw four specific conclusions in relation to value for money in
Ireland’s public water services sector. (p.146 - 147 ).
1. While unit costs such as cost per p/e can be calculated, “they are very location specific
and only limited interpretation of them is possible”. The market competition offered
by DBO contracts, rather than traditional procurement, provides a better chance that
the most cost effective solution for a location will be secured.
45
2. Positive benefit/cost ratios only provide reassurance that projects are worthwhile, but
not whether they achieve maximum efficiency.
3. There is clear evidence that larger schemes with high density catchments involve
lower unit cost. However, in lower density areas, the pumping costs of water over long
distances outweigh the benefits of larger plant economies of scale. The second point is
particularly relevant to Group Schemes, when considering the cost alternatives of
building a small stand alone water treatment plant to connection to the nearest public
main or connection to a larger Group Scheme plant some distance away.
4. Many of the main Value for Money (VFM) issues in the water sector relate to macromanagement issues rather than micro project level cost efficiencies. “They relate to
whether, however cost effectively or ineffectively, we are producing more water than
we need, losing more than we need consuming more than we need and treating more
than we need. If we are doing more than we need, no amount of project-level
efficiencies will get away from a situation of poor value for money” (p.147.). This
comment relates to the whole water sector in Ireland rather than the Group Water
sector but it illustrates that many of the issues in the Group Schemes sector in relation
to water conservation, leakage and metering are mirrored if not magnified in the
public water sector.
Fitzpatricks points out that the lack of metering and water charging of domestic households
on the public water supply means that water leakage and overuse cannot be monitored. It
states that the National Federation of Group Water Schemes (NFGWS) has estimated that the
cost of metering a new house is €50 and it is €250 for an existing house (p.152). [The
Department’s Inspectorate believes that this figure is too low and that a more realistic cost
estimate is €600 rather than €250 per existing house]. Fitzpatricks draws an unfavourable
comparison between the management of the water services and the ESB system in terms of
lack of management information (p.153.). The current management of water services in
Ireland is akin to “attempting to run a national electricity grid without electricity meters.”
(p.155.).
46
This report is important as it explores several themes relevant to the Group Water sector and
adds to the body of knowledge on the water treatment system in Ireland. The most significant
point that it makes from the perspective of this study is the difficulty with making cost
comparisons and benchmarking in the water services sector.
A “distinct feature of the sector, which has very direct relevance to any evaluation that
addresses value-for-money issues, is that water infrastructure and plant is designed on a quite
bespoke basis for particular locations. In practice this makes benchmarking and cost
comparisons across projects and locations even within Ireland, never mind internationally,
difficult.” (2005, p.6.)
This point will have to be borne in mind in designing a methodology for analysing the value
for money of the Rural Water Programme.
Expenditure Review of Exchequer Financed Water and Sewerage Schemes
This Review was submitted to the Department of Finance in December 2002 and made the
case for continued funding of this programme. The objectives of the programme were, inter
alia, to meet domestic and broader economic water and sewerage treatment needs and to
comply with various EU directives, to reduce environmental pollution. The Review referred
to the Government policy that there should be full cost recovery of the operation and
maintenance cost of providing water services to the non-domestic sector. It also states that
there should be cost recovery of the marginal capital cost of infrastructure provision for nondomestic purposes (p.28.). The Review explained that due to the varied size of schemes under
the Programme, it proved difficult to assess the overall effectiveness of the programme. As
there was no common cost benefit technique available, it was decided to take a number of
schemes varied as to size, objective and location and assess each scheme by way of a multicriteria analysis. The same methodology was used in the Mid-Term Evaluation of the
Operational Programme for Environmental Services 1994-1999 (p.30.). The multi-criteria
analysis looked at the various impacts of the Schemes but did not involve a financial analysis
apart from a reference to final scheme cost and whether the tender price was exceeded. The
Review also refers to weaknesses in the water distribution system due to substantial losses
through leakage (p.25 & 58.). The Expenditure Review concluded that “the continued
availability of exchequer funding in addition to the other specified funding sources is vital to
ensure that we are able to meet the demands of our growing economy and achieving an
47
appropriate balance between the requirements of that economy and the protection of our
environment” (p.61.). It is interesting that in this report too there are difficulties expressed in
relation to comparing and assessing the relative cost effectiveness of various water projects.
The alternative multi-criteria analysis approach used very little financial data but there is
obviously a subjectivity problem in determining the weighting for different criteria for this
approach.
Mayo Bundle 2 – Leakage Control Strategy – March 2005
The above reports have highlighted the problems of water leakage and the need for greater
water conservation in the Irish water services sector. In 2004, Ryan Hanley Engineering
Consultants were commissioned to carry a leakage control study of group schemes in Co.
Galway and in 2005, they were engaged by Mayo County Council to carry out a similar study
of Mayo group schemes. These studies are very significant as they provide a clear illustration
of the problems with Unaccounted for Water (UFW) in the group scheme sector and an
economic assessment of the most cost effective approach to addressing this issue. The
counties involved are also very significant as Galway and Mayo have respectively the greatest
and second greatest number of group schemes in the country. Over 60% of the schemes
requiring upgrading, to comply with the Drinking Water Regulations, are located in these two
counties. Both leakage control reports follow a similar format so the Mayo Report will be
considered here, as it is the most recently published of the two reports.
The Mayo Leakage Report looked specifically at 21 group schemes being considered for the
procurement of DBO treatment plants together as Mayo DBO Bundle No. 2. The Leakage
Control Strategy found that bursts and leakage represent the single largest component of
UFW, which was estimated to be “between 26.3% and 79.9% of total demand” on individual
Group Schemes in the Mayo Bundle No. 2 (2005, p.5). The report states, “rural schemes also
generally exhibit a higher percentage loss than urban systems, simply because of the much
greater pipe length required per consumer” (ibid). It acknowledges, “it is unrealistic to expect
any buried system to be leak free” which is why the target UFW level of 25% set by the
Department is a reasonable one (p.8.). The report predicts “that there would be a progressive
increase in unaccounted for water over time” in the absence of remedial measures (ibid, p.6.).
48
It is explained that a “strategy for leakage control is governed by three main factors:
a) Security of Supply – the need to keep demand below the reliable yield of the raw
and treated water resource facilities, thus avoiding the need for rationing or other
demand control measures which impact on the community,
b) Economics – the reduction of leakage levels to point where the additional cost of
saving an extra cubic metre of water is more than the cost of producing it, and
c) Environmental – the impact on the natural environment of the abstraction of water
that is not beneficially utilised”. (ibid, p.8)
From an economic and value for money perspective, the report found that out of 21 group
schemes in Mayo Bundle No. 2, it was cheaper to carry out leakage control measures on 19 of
the schemes rather than build additional water treatment plant capacity to allow for continuing
water wastage at the existing UFW levels. In the case of the other 2 schemes, building
additional treatment capacity would not be sustainable in the future due to worsening UFW in
one case and in the other case, the additional treatment capacity would have placed too much
abstraction demand on the water source (p.1.), with possible knock on environmental
consequences for fish, flora and fauna (p.11.). These findings are significant as they
demonstrate that UFW represents a significant additional capital and current cost for water
treatment on group schemes and that targeted leakage control measures can significantly
reduce these costs. The report also makes some pointed remarks about the absence of water
meters on the Mayo Bundle No. 2 group schemes at that time. “The installation of consumer
meters should lead to a significant reduction in waste, as many consumers will be unaware of
what normal consumption for their premises should be. The fact remains that without
metering there is no incentive to conserve water and minimise waste” (2005, p.13.). As
already discussed in the Fitzpatrick Associates’ report, these remarks, about the lack of
metering of domestic connections, are just as relevant to the public water supply sector as to
the group scheme sector.
49
Rural Water Programme - Outputs Measurement
Report to the European Commission on measures to bring Group Water Schemes into
compliance with the Drinking Water Directive – Department of the Environment, Heritage
and Local Government - June 2006
This Departmental report is vital in providing a detailed picture of progress to date in
upgrading all Group Schemes, subject to the ECJ ruling. As well as a national overview, it
provides breakdowns of implementation on a county, solution and scheme by scheme basis.
This report measures outputs from investment to date under each water quality upgrade
solution. The lists of upgraded schemes will facilitate the selection of a number of group
schemes, under each treatment solution, for case study review. The report is more a
quantitative update of programme implementation rather than an analytical review. However,
it appears that implementation of the Design Build Operate (DBO) standalone treatment
solutions is far more advanced than the two solutions involving connection to the public
mains. This Review will examine the reasons for this apparent imbalance in programme
implementation to date in Chapter 4.
Rural Water Programme – Outcomes Measurement
The Quality of Drinking Water in Ireland – A Report for the Year 2005 (Environmental
Protection Agency 2007)
In many respects, this is the most important report in this Literature Review as it goes right to
the heart of the issue driving investment under the current Rural Water Programme. The EPA
publishes a drinking water quality report each year based on the results of water testing
carried out by local authorities, as required under the 2002 Drinking Water Regulations. The
report estimates that 6.4% of the total population is served by private group water schemes
and 3.4% by public group water schemes (p.9). Previous reports have highlighted problems
with water quality on privately sourced Group Schemes in particular and the 2007 Report is
no different. It states in unambiguous terms that in 2005 the “quality of drinking water
supplied to public group schemes was satisfactory while the quality of drinking water
supplied by private group schemes was unsatisfactory” (p.56.). The report also comments that
50
the “high percentage of samples indicating contamination with E.coli in the private group
water schemes is of great concern” (p.20.) It was also noted that in 2005 “for the first time in
5 years there has been an increase in the percentage of samples contaminated with human or
animal waste”(ibid).
The Report explains that there are 46 water quality parameters under the 2000 Drinking Water
Regulations broken down into the categories of microbiological, chemical and indicator
parameters. Water samples, for each Group Scheme required to comply with the Drinking
Water Regulations, must be tested at least twice a year. Where a microbiological or chemical
parameter exceedance occurs on a Group Scheme, the local authority is required to serve a
notice on the person responsible for the supply within 14 days of receipt of the results. The
notice must require the Group Scheme to prepare an action plan within 60 days of receipt of
the initial result. The measures proposed in the action plan must be implemented within one
year for failures that present a risk to public health and within two years for exceedances that
do not present a risk to public health. In the case of an indicator parameter exceedance, the
Council must first determine whether or not the exceedance poses a risk to human health. If it
does, the Group Scheme is required to carry out the corrective actions already outlined for a
microbiological or chemical parameter exceedances (2007, p.6-7.).
The report recommends that “sanitary authorities should ensure each group water scheme
(public or private), where microbiological quality problems were identified, has an action
programme prepared to address the quality deficiency” (ibid). It also recommends that in
cases where group schemes have not prepared an action plan to improve the quality of their
water supply or have failed to implement it “the sanitary authority should use all the
enforcement powers available to it to rectify problems including, where necessary,
prosecution.” (p.56-57). County Councils, as sanitary authorities, are empowered to take
prosecutions against non-co-operative Group Schemes under the 2000 Drinking Water
Regulations and have been given additional powers to take remedial action themselves under
the updated 2007 Drinking Water Regulations. The EPA noted that “no local authority
audited by the Agency during the year [2005] had taken enforcement action to ensure
compliance in the quality deficient group water schemes”(2007, p.1.). The report also
comments that
51
“In spite of record levels of investment in the group water schemes sector, progress in
upgrading schemes is simply not happening at a fast enough speed. Furthermore, while the
majority of schemes have action plans in place to address the quality deficiency, a sizeable
number of schemes have prepared no corrective action plan.”(2007, p.2.).
In relation to group water schemes being supplied from the public mains, the report
recommends that the group scheme operators “should ensure that the quality of the water
supplied by the sanitary authority does not deteriorate in the group water schemes distribution
network”(p.57.) This point is very significant as connecting a group water scheme to the
public mains considerably reduces the risk of poor quality water, however, there is a risk of
re-contamination if the pipe network is not properly maintained.
One issue that the EPA is very critical of is the lack of adequate water quality monitoring by
the local authorities, particularly of the Group Schemes’ sector. All Group Schemes, required
to comply with the Drinking Water Regulations, must be tested at least twice a year and more
often in the case of larger Group Schemes. In many cases, Group Schemes are being tested
inadequately or not at all. In 2005, 65% of publicly sourced Group Schemes and 41.2% of
private Group Water Schemes were inadequately monitored. 9% of private group water
schemes were not monitored at all in 2005. “People supplied by these schemes may be
drinking contaminated water but may not even be aware of the fact that their water is unfit for
consumption” (2007, p.12.). The EPA also identified a specific issue with regard to the lack
of testing of small group schemes serving less than 50 people but supplying water to a
connection with a commercial or public function. Such schemes must also comply with the
Drinking Water Regulations. The EPA found that such schemes had not even been identified
never mind tested in 6 out of 7 counties audited by them (2007, p.47.). It must be
remembered though that this is an assessment of local authority monitoring in 2005 and that
the situation may have improved in 2006. Departmental officials reminded local authorities of
their statutory water quality testing duties at a conference of Rural Water Liaison Officers on
June 8th 2006. The EPA have been given greater powers, under the 2007 Drinking Water
Regulations, to take legal enforcement action against Councils that fail to carry out their
monitoring duties adequately.
52
From the perspective of this value for money review, this Drinking Water Quality Report will
be a crucial tool in measuring programme outcomes. Compliance with the regulation requires
water at the household tap to be of adequate quality. Therefore, the completion of treatment
solutions for Group Schemes is only a measurement of outputs as it is not guaranteed that
clean water from the DBO treatment plant or public water supply will come out of household
taps in the same condition. As already stated above, there is a risk of re-contamination in
poorly maintained Group Scheme pipe networks (2007, p.57.). Water samples are tested at the
household taps so this is the true measurement of compliance or non-compliance with the
Drinking Water Directive. A CD accompanies the Drinking Water Report, which should
contain water quality test result data for every Group Scheme required to comply with the
Drinking Water Regulations. A number of Group Schemes upgraded prior to 2005 will be
selected and their test results for 2005 will be checked to verify that these upgraded Group
Schemes were in fact compliant with the Drinking Water Regulations in 2005. If the
completed Schemes are still non-compliant it casts a question mark over the effectiveness of
that treatment solution and the financial investment in it. The measurement of outcomes will
be discussed further in the methodology chapter.
The 2007 EPA drinking water quality report makes stark reading for the group schemes
sector. If nothing else, the fact that a report on the state of drinking water supplies nationally
focuses so much on a sector that serves less than 7% of the entire population says a lot. It
must, however, be reiterated that these figures are based on 2005 data and do not take into
account water quality improvements since then. That said, the level of implementation of the
rural water plan by June 2006 was still relatively modest, particularly in relation to solutions
involving connection to the public mains. There are numerous practical problems in trying to
persuade private volunteer based community water schemes to engage with the rural water
programme so the local authorities job is far more complicated than dealing with public water
supplies. The prosecution of some group schemes trustees could “inevitably result in
committees of management simply ‘walking away’ (rather than being held legally
accountable) and schemes collapsing” (NFGWS submission-Appendix 3). However, nonaction is simply not an option on public health grounds. Ultimately, “it is unacceptable for
persons responsible for the management of group water schemes to supply water to members
of the public that is contaminated with human or animal waste” (EPA 2007, p.42.).
53
Conclusions
As can be seen from this literature review, the water services sector in Ireland and specifically
the Group Scheme sector is highly complex and diverse. Professor Daly’s “The Buffer State”
demonstrates that the Group Schemes’ model was the preferred approach of rural Ireland, or
at least its representatives, for the provision of piped water supplies to remote areas of the
country. The 1989 Review of the Group Schemes’ Programme begins to mark the shift in
emphasis of the programme from a water supply to a water quality objective. The Action Plan
for Rural Drinking Water Quality 2003-2006 marks the development of a coherent strategy to
tackle the problems of water quality in the private Group Scheme sector, in particular, in order
to avoid major EU fines for non-compliance with the Drinking Water Directive. The Action
Plan also shows that there is no “one size fits all” treatment approach to solving these
problems and that co-operation with all stakeholders in the Group Schemes’ sector is vital for
success. The National Federation of Group Water Schemes recognise that the issues of water
conservation and source protection will become more and more vital in the future. They also
recognise that the future viability of smaller privately sourced Group Schemes is questionable
given the additional costs of water treatment.
The 2006 Fitzpatrick Associates National Review of the Water Sector raises many issues
relevant to both the public and group schemes sector and specifically the ongoing problems of
Unaccounted for Water (UFW) and the need for greater water conservation. In the context of
VFM methodological approaches, the Fitzpatricks report and the 2002 Expenditure Review
both question the usefulness of a comparative unit cost approach based on Cost per head of
population (p/e) [or cost per house in the case of Group Schemes] due to the bespoke nature
[i.e. individual custom made design] of individual water treatment plants serving population
catchments of widely differing densities. They regard issues such as procurement approaches
and leakage control as providing better indications of value for money. The latter issue is
borne out by the findings of the 2005 Leakage Control Strategy for Mayo Bundle No. 2. Other
methodological based literature will be considered in Chapter 3 on methodological
approaches.
54
Ireland compares relatively well by comparison to other EU states in relation to our
information gathering on private water supplies. Irish grant aid to the group schemes’ sector is
relatively generous by comparison to Scotland. However, the Scottish focus on mandatory
risk assessment and source protection could provide a model of best practice for Ireland.
Finally, the Department’s June 2006 Report to the European Commission and the EPA’s
Drinking Water Quality Report for 2005 will provide an invaluable source of output and
outcome verification data for the purposes of this Value for Money Review.
55
Chapter 3
Methodological approaches
56
Introduction
The primary objective of a methodological approach is to derive a systematic means of
satisfactorily addressing each of the terms of reference for this Value for Money Review.
Therefore, each of the terms of reference will be considered in turn in this chapter and the
methodological approach will be outlined. The data required and how it was sourced will also
be discussed. Finally, the reasons for this methodological approach and its limitations will be
considered.
Efficiency and Effectiveness Issues
The main purpose of this Value for Money Review is to determine whether the objectives of
the Action Plan for Rural Drinking Water Quality 2003-’06 are being achieved using an
efficient level of resources. As previously stated, the Programme outcome i.e. objective is to
ensure that the water coming out of household taps in Group Water Schemes serving 50 or
more persons meet EU drinking water quality standards. The programme inputs is the
expenditure incurred on water quality upgrade solutions as well as investment in source
protection and pipe distribution system upgrades. The Programme outputs are the completion
of infrastructure works and the production of treated water. It is usually more difficult for
VFM Reviews to assess whether outcomes have been achieved as a result of Programme
investment. In this case, it is relatively straightforward as the water coming out of household
taps will either pass or fail the drinking water standards, thus measuring a positive or negative
outcome.
It is more difficult, in this case, to measure whether the investment in Programme inputs
delivered outputs in the most cost efficient manner due to the number of different water
quality upgrade solutions and the fact that no two water schemes are identical from a
comparative perspective. The main issue here is whether it was more cost efficient to pipe and
pump water out from the nearest public supply or alternatively to build or upgrade a small
treatment plant to serve the Group Water Scheme or Group Water Scheme sub-bundle. Did
local authorities carry out a robust assessment of the comparative costs? Also, most
expenditure is focused on treatment solutions but would it not be more cost effective to invest
more in source protection to reduce treatment costs. Similarly, after water treatment, it is quite
possible that water may become re-contaminated in sub-standard Group Water Scheme
57
distribution systems or treated water may be lost through Unaccounted for Water (UFW).
These issues must be considered when designing a methodology for assessing the
effectiveness and efficiency of Rural Water Programme investment.
Data Requirements and sources
As the management of the Rural Water Programme is devolved to County Councils, most of
the financial data on specific Group Schemes was obtained from the local authorities. In the
case of DBO treatment plants, financial data was obtained directly from the DBO client
representatives employed by the Councils and the Group Schemes to oversee the DBO
contractors. Data in relation to overall programme implementation was sourced from the June
2006 Report to the European Commission and the attached Questionnaire, which was
completed by all County Councils (Appendix 4). Data in relation to programme effectiveness
was obtained from the most recent water quality test results, published by the Environmental
Protection Agency (EPA), for 2005 (EPA, 2007). Water quality data, post 2005, was
requested from local authorities.
Stakeholder Consultation
It is vital that stakeholder consultation is carried out as part of this Review, particularly given
that it is a local authority managed programme and also because all of the Group Water
Schemes are in private ownership. All County Councils administering Group Water Scheme
upgrades were invited to make submissions in addition to completing the attached
questionnaire. The Questionnaire approach was chosen to provide a structured means of
collecting the necessary data from County Councils to address the terms of reference of the
Value for Money Review. The issues raised in the Questionnaires were based on
conversations with Departmental staff and a review of previous studies on investment in water
treatment infrastructure. Both administrative and technical Departmental staff were consulted
in relation to the Questionnaire before it was issued to local authorities. Officials from Mayo
and Sligo County Councils were also asked to make comments on the draft Questionnaire
prior to issue.
All of the member groups of the National Rural Water Monitoring Committee were also
invited to make submissions relevant to the Review’s terms of reference. Specific questions
58
were addressed to the National Federation of Group Water Schemes (NFGWS) as the
recognised representatives of the Group Water Scheme sector. The Drinking Water Unit of
the European Commission’s Environment Directorate were also invited to make a submission.
The National Federation of Group Water Schemes (NFGWS) made the only submission,
which is attached in Appendix 3.
Methodology for addressing the Review’s Terms of Reference (in italics)
Identify programme objectives
The Programme objectives were identified in Chapter 4 by examining the objectives set out in
the Action Plan for Rural Drinking Water Quality 2003-’06. The primary objective of the
Action Plan is to upgrade drinking water quality for Group Water Schemes serving greater
than 50 persons so as to comply with the European Union’s 1998 Drinking Water Directive.
Subsequent Departmental Circulars to local authorities were also examined to verify
programme objectives.
Examine the current validity of those objectives and their compatibility with the overall
strategy of the Department of the Environment, Heritage and Local Government.
The current validity of these objectives was assessed in Chapter 4. The June 2006 “Report to
the European Commission on Measures to bring Group Water Schemes into compliance with
the Drinking Water Directive” and the latest Environmental Protection Agency (EPA) reports
on drinking water quality were examined to assess the current state of drinking water quality,
in the Group Schemes’ sector. The objectives of the Action Plan for Rural Drinking Water
Quality 2003-’06 were also compared with the relevant objectives of the current Strategy
Statement of the Department of the Environment, Heritage and Local Government to verify
their compatibility.
Define the outputs associated with the programme activity and identify the level and trend
of those outputs
The programme outputs and level and trend of these outputs were identified in Chapter 4 by
comparing the objectives of the Action Plan for Rural Drinking Water Quality 2003-’06 with
the most up to date and comprehensive information on programme implementation i.e.
59
completion of Group Scheme upgrades available in the June 2006 Report to the European
Commission. In addition, all County Councils were asked to respond to Questions 5 to 10 in
the attached Questionnaire (Appendix 4). These questions ask Councils to explain delays in
programme implementation in general and also delays in implementing particular upgrade
solutions. Councils are also asked to identify any additional measures needed for successful
programme implementation.
There are also other works ongoing, under the Group Schemes’ Programme, in addition to the
water quality upgrade solutions. These include New Schemes, Scheme Extensions and Pipe
Network Upgrades. As the June 2006 Report does not contain output data on these activities,
Councils were asked to provide details of output activity for these elements over the 2003-’06
period in their Questionnaire returns (Appendix 4 – Q23-Q25).
Examine the extent that the programme’s objectives have been achieved, and comment on
the effectiveness with which they have been achieved
The effectiveness of the Rural Water Programme is equally if not more important than its cost
efficiency, given its public health significance. The only test of this is whether Group
Schemes comply with the Drinking Water Regulations after they have been upgraded. The
Regulations set out 46 parametric values for drinking water quality broken down into three
categories, Microbiological (2), chemical (26) and indicator parameters (18). These
parameters are listed in Appendix 5. If a water supply, covered by the Regulations, exceeds
any of the microbiological or chemical parameters, the Group Schemes is required to take
action to remediate this situation. In the case of indicator parameters, remedial measures are
only required if the parameter exceedances pose a threat to human health. Therefore, at a
minimum, treatment solutions are required where microbiological or chemical parameters are
exceeded otherwise the public or private water supplier is non-compliant with the
Regulations. Local authorities are required to monitor water supplies in their administrative
area and carry out testing on water samples as laid down in the Regulations. County Councils
must test all Group Schemes, whether connected to the public supply or on a private water
supply. These test results are then submitted to the EPA, who can audit them and also verify
that local authorities have carried out sufficient testing. The most up to date test result data
published by the EPA is for the year 2005 (EPA, January 2007).
60
A number of Group Schemes upgraded in the 2003-’06 period were selected from each of the
five treatment solution categories. The EPA test results for the Schemes, in the year after
upgrading, were checked to verify if that Scheme was compliant. If the Group Scheme water
samples do not exceed any of the microbiological or chemical parameters after being
upgraded, the treatment solution can be deemed to have achieved a successful outcome and be
considered effective. If alternatively, the samples still show exceedances for these parameters
after upgrading, then the Group Scheme is still non-compliant with the Drinking Water
Regulations. In this case, a successful outcome was not achieved and the treatment solution
used was not an effective use of public money. It should be noted that since the most recent
published EPA data is only up to 2005, local authorities were asked to provide data on water
quality results for Schemes upgraded from 2005 onwards.
Overview data on effectiveness was also gathered by requesting all County Councils to
respond to Questions 11 to 12 in the attached Questionnaire (Appendix 4). Councils were
asked to

Confirm that all Group Schemes, which have been completed i.e. upgraded under the
Action Plan, now fully comply with the Drinking Water Directive i.e. have achieved
their programme objectives.

Identify any risk factors, which could impact on the sustainability of the completed
water quality upgrade solution e.g. water source contamination or recontamination of
water in the pipe network.

Confirm that they have an active monitoring system in place to verify that the quality
of water coming out of household taps in the upgraded Group Schemes is compliant
with the Drinking Water Directive.
61
Identify the level and trend of costs associated with the Action Plan for Rural Drinking
Water Quality 2003-’06 and thus comment on the efficiency with which it has achieved its
objectives
The level and trend of costs associated with the Action Plan for Rural Drinking Water Quality
2003-’06 was identified based on Departmental grants to local authorities and expenditure
returns from local authorities for the 2003-’06 period. The efficiency of this expenditure was
assessed by both an overview of local authority cost control practices and an examination of a
number of case study schemes for each of the water quality upgrade solutions.
Overview of cost control practices
A general survey of each Council’s cost control practices was carried out to assess the overall
efficiency with which the Action Plan has been implemented. All County Councils were
asked to respond to Questions 1 to 4 and 14 to 22 in the attached Questionnaire (Appendix 4).
A comparative analysis of all Councils’ responses to the Questionnaire was also carried out.
The questions sought to address the following issues:

Were all water quality upgrade solution options considered and was the most cost
efficient treatment solution adopted e.g. connecting the Group Water Scheme to the
public water supply rather than building a dedicated water treatment plant?

Was competitive tendering used to ensure that the most cost efficient contract was
awarded and was the most cost effective procurement route used?

Was the cost efficiency of connecting a number of schemes to the same treatment
plant considered?

Were treatment plants built with the most cost efficient design capacity i.e. sufficient
water treatment capacity to deal with current and future development water demand
but with minimal allowance for water wastage (UFW) in the Group Schemes pipe
network distribution systems?
62

In cases where Group Schemes receive their water from the public water supply, how
does the Council charge domestic and non-domestic consumers for their water supply
and how do these charges compare both across Councils and to charges for non Group
Scheme customers?
Efficiency analysis of case studies for each upgrade solution
A more detailed analysis was also carried out of the cost of upgrading the water quality of a
sample of schemes for each solution type. The same upgraded Group Schemes already
selected for the effectiveness analysis were used in the efficiency assessment. Firstly, it was
verified whether the cost control practices already outlined above were observed in the case of
each upgraded scheme. The relative upgrading cost [i.e. cost per house] of Group Schemes
were examined to assess cost efficiency. For each of the case study schemes;

The relative cost of upgraded schemes with the same water quality upgrade solution
was compared

The relative cost of completed schemes with different upgrade solutions was
compared
There are limitations to this comparative methodological approach, which will be explained
later on in this chapter, but it provides transparency on the relative cost to the exchequer of
these upgrading solutions. It also provides a means of verifying that the responses provided
by local authorities in the general survey are reflected in their implementation of individual
Group Scheme upgrades. Care had to be taken to ensure that additional costs involved in
bringing the Group Schemes into compliance with the Drinking Water Directive were
factored into the overall cost of the upgrade solution e.g. the cost of upgrading the pipe
network in addition to the cost of the water quality upgrade solution. Pipe network upgrade
cost data was generally not available for DBO projects as these works are only getting
underway in many cases.
One of the benefits of DBO projects is that the whole life costs of the treatment plants, known
as the Operational and Maintenance (O&M) costs, are set out in the DBO contract. However,
63
there are methodological problems in making comparisons with the O&M costs of local
authority public water supplies as explained in the section on unit costs below.
Evaluate the degree to which the objectives warrant the allocation of public funding on a
current and ongoing basis and examine the scope for alternative policy or organisational
approaches to achieving these objectives on a more efficient and/or effective basis.
The continued need for public investment in the Rural Water Programme under future post
2006 Action Plans was assessed in Chapter 5 based on programme implementation to date to
bring Group Schemes serving greater than 50 persons into compliance with the Drinking
Water Directive. It was also assessed whether additional investment, over and above present
commitments, will be required in the future e.g. upgrades of Group Schemes serving less than
50 persons.
Various alternative policy and organisational approaches for achieving programme objectives
were also considered and analysed based on consultations with stakeholders and other
relevant/interested parties. The potential effectiveness and cost efficiency of these alternative
approaches was considered. For example, the current policy focus is meeting objectives
through ‘end of pipe’ solutions through the treatment of sub-standard water. There is an
alternative view that it would be more effective to invest in source protection measures to
protect the quality of water sources and reduce contamination of the raw water in the first
place.
Specify potential future performance indicators that might be used to better monitor the
performance of future Action Plans for Rural Drinking Water Quality
Key programme performance indicators and management information data needs were
identified during the course of this Review. Recommendations are made in relation to the
future collection and use of such indicators in Chapter 6 of this Review.
64
As the administration of the Rural Water Programme is largely devolved to local
authorities, the efficiency and effectiveness of the local government system in meeting the
objectives of the Action Plan for Rural Drinking Water Quality 2003-’06 will be assessed
The role of local authorities in implementing this devolved Programme was assessed as part
of the methodological approaches already outlined above. Individual County Councils are
responsible for Programme implementation, efficiency and effectiveness in their areas. The
role of local authorities in programme implementation was reviewed in the context of
alternative organisational approaches in Chapter 5.
Methodological issues
In measuring the comparative cost of different water quality upgrading projects, one has to be
mindful of comparing ‘like with like’ (Mulreany 2002, p.18). In “Economic and Financial
Evaluation – Measurement, Meaning and Management”, Mulreany identifies a number of
measurement difficulties and diseases. He gives the example of a surgeon in an urban area
seeing more patients and performing more operations than his peer in a rural area. It cannot be
assumed however that the urban surgeon is more efficient than his rural counterpart as he has
greater ease of travel and serves a higher population density (ibid). Therefore, one is not
comparing like with like. The relative cost efficiencies issue of delivering services to rural
areas is very relevant to this study.
Coombs and Jenkins also examine the issue of unit cost comparisons in “Public Sector
Financial Management” (2002). While unit costs are a good way of measuring the efficiency
of the same organisation over a period of time, they have several limitations. One of those
issues is, yet again, comparing like with like. Coombs and Jenkins use the very relevant issue
of the comparative cost of delivering services to urban and rural areas (2002, p.36.). Another
shortcoming of unit cost comparisons is that they measure efficiency rather than effectiveness
(p.34). As will be seen in Chapter 4, that point is very relevant to this Review. The
Disinfection/Sterilisation water quality upgrading solution is clearly the most cost efficient on
a capital cost per house basis but its effectiveness and sustainability is in question.
65
As already discussed in the literature review, in reviewing previous studies on public water
services infrastructure, similar methodological problems are raised in relation to assessing the
performance of public water treatment projects. The 2005 Fitzpatrick Associates’ Evaluation
of Water Services Investment under the NDP 2000-’06 explained that due to the bespoke
nature of many water treatment schemes (p.5-6. & p.121.) serving widely varying population
densities, it is not possible to set precise benchmarks in terms of cost efficiency. “What may
be good value in one place may be bad value in another: depending on circumstances” (ibid,
p.131.). This problem is even more exacerbated under the Rural Water Programme due to the
geographical dispersion of populations being served and the cost of distributing piped water
of adequate quality to these often outlying areas by comparison with urban centres. Also, the
use of five different water quality upgrading solutions means that it will be difficult to reliably
compare the cost of different solutions e.g. comparing the cost of connecting a Group Scheme
to an existing public water supply to the cost of building a treatment plant for the Group
Scheme.
A 2002 Expenditure Review of Exchequer financed Water Services Schemes used multicriteria analysis to assess the overall effectiveness of the programme based on the precedent
of the Mid Term Evaluation of the Operational Programme for Environmental Services 19941999. However, this approach gave very little information in relation to the cost efficiency
with which the Programme under review was implemented. Also, Multi-Criteria analysis can
be quite subjective in weighting the relative importance of different criterion (Regulatory
Impact Assessment Guidelines 2005, p.116.).
Given the difficulties in making reliable ex-post unit cost comparisons and the vagaries of
multi-criteria analysis, the verification of pre-project appraisal comes to the fore in trying to
review value for money decision-making. Basically, did the local authority consider all
options at the start in determining which water quality upgrade solution to adopt. The
Department of Finance’s “Guidelines for the Appraisal and Management of Capital
Expenditure Proposals in the Public Sector” advises that all options for achieving project
objectives should be identified, considered and costed (February 2005, p.33.). The Guidelines
specifically emphasise the importance of objectivity as “there is a danger that the selection of
options may be manipulated in order to make a case for a course of action which is already
66
favoured” (ibid). This is a very relevant point when carrying out a Review of the Rural Water
Programme where more than one water quality upgrade option was available. For example,
there is anecdotal evidence backed up by local authority questionnaire responses that some
Group Schemes favour the construction of standalone DBO treatment plants over connection
to the public mains, due to local authority water charges for non-domestic users. It is
important, therefore, that the Value for Money Review verifies that different options were
costed and that the most economically advantageous option was selected as specified in the
National Rural Water Monitoring Committee’s guidance documentation to local authorities
(June 1999, p.2.14 ) (May 2002, p.4.7). This was the motivation behind Questions 1 and 2 in
the attached Questionnaire to local authorities (Appendix 4)
In many cases, however, the remoteness of a Group scheme from the public mains may mean
that the construction of a DBO water treatment plant was the only technical solution available
to upgrade the water quality of the Group Scheme. The issue of procurement then comes to
the fore in ensuring that the contract that goes to tender has been designed so that the most
competitive market bids will be attracted. As already discussed in the literature review,
Fitzpatrick Associates have argued that the market competition offered by DBO contracts,
rather than traditional procurement, provides a better chance that the most cost effective
solution for a location will be secured (2005, p.146.). An analysis of the viability of
rationalising the number of DBO water treatment plants needed through connecting two or
more Schemes to the same plant may also achieve greater cost savings. Questions 3 and 4
were put to local authorities to measure the usage of procurement strategies to achieve
efficiency savings, particularly where the alternative option of connection to the public mains
was not available.
A significant proportion of investment to date under the current Rural Water Action Plan has
gone on the construction of DBO water treatment plants. While it will be difficult to make
reliable comparisons of the relative costs of the pipe networks connecting the treatment plants
to households, it should be possible to roughly compare the cost of the treatment plants on a
cost per house basis. Another measurement issue to be careful of is that significantly larger
treatment plants will have economies of scale relative to smaller plants although generally
67
Group Scheme plants are smaller relative to those constructed for public water supply
schemes because of their smaller population catchment.
In any case, it is vital that even with the comparative problems stated above, that the full cost
of bringing individual Group Schemes into compliance with the Drinking Water Directive
under the different upgrade solutions are compared from the perspective of transparency and
accountability to the taxpayer. Therefore, the upgrade cost per household in Group Schemes
will be used as a basis for making rough cost comparisons between solutions, subject to the
substantial qualifications already outlined above.
Operation and Maintenance Unit Cost Issues
Unit cost approaches are also used in calculating the operation and maintenance (O&M) costs
of supplying a certain quantity of water to the public or private group schemes sector. There
is, however, no standard method in Ireland for calculating the unit cost of supplying treated
water. Local authorities use different methodological approaches for calculating their O&M
costs based on allocating various overheads incurred by the councils in managing the
production and distribution of treated water to households. North Tipperary County Council
have developed a standard template for calculating local authority water costs and charges,
which has been made available to other Councils on the Water Services National Training
Group’s website (www.wsntg.ie). This template is for guidance purposes only and allows for
Councils to add or subtract overheads to the template to fit with their own cost absorption
policies. Coombs and Jenkins also highlight the issue of different overhead apportionment
systems in UK local authorities, which makes reliable inter-authority cost comparisons
extremely difficult (2002, p.37.).
The current position is that capital works for constructing public water schemes are funded by
direct capital grants from central government. The O&M costs for the supply of non-domestic
water supplies is fully recouped from the commercial sector. The O&M costs of supplying
public water to the domestic sector is recouped by local authorities from central government,
through the Local Government Fund (LGF). The recoupment of domestic water O&M costs
is not ring fenced within the Local Government Fund so it’s not clear to local authorities
which element of their LGF receipts are water and non-water. The public schemes sector lies
68
outside the terms of reference of this study but it is instructive to note the non-existence of a
standard water unit cost for either capital works or O&M costs at local authority level. This
makes it particularly difficult to compare the O&M costs of different local authorities and also
to make comparisons with Group Schemes O&M costs. This was an important issue in trying
to compare the O&M cost of supplying treated water to a Group Scheme from a public water
supply to the O&M costs of running a Group Scheme water treatment plant, in Chapter 4. It
was not possible to include the Disinfection/Sterilisation and non-DBO solutions in this
comparative O&M exercise as their water treatment infrastructure is maintained voluntarily so
no O&M cost data is available. The Department may wish to look at the issue of standardising
the calculation of local authorities’ O&M costs for public water services, for comparative
purposes, in a future study.
69
Chapter 4
Analysis and Findings
70
Table of Contents
Overview
p.72.
DBO Solution
p.86.
Non-DBO Solution
p.108.
Public Water Supply Solutions
p.113.
Disinfection/Sterilisation Solution
p.129.
Comparison of solution costs
p.141.
Network Upgrades and Leakage Control
p.143.
Rural Water Subsidy
p.152.
New Group Schemes
p.159.
71
Overview
Introduction
In this chapter, the terms of reference of the Review will analysed using the methodological
approach set out in the previous chapter. As there are five different water quality upgrade
solutions being implemented under the current Action Plan, the outputs/programme activity,
effectiveness and efficiency elements of the terms of reference will be addressed individually
for each treatment solution. There will also be some comparisons made between the
implementation, effectiveness and efficiency of the water quality upgrade solutions as well as
comparisons with the public schemes sector. The new group water schemes and pipe network
upgrade measures will also be considered as well as the annual operational subsidy for
domestic water consumers on group schemes.
Terms of Reference No. 1
Identify programme objectives
The primary objective of the Rural Water Programme during the period of the Action Plan for
Rural Drinking Water Quality 2003-2006 is to bring “the quality of rural water supplies into
compliance with the Drinking Water Regulations 2000, and to achieve this within the shortest
possible timeframe” (Foreword). Departmental Circular letter L11/2004 to County Councils
states that “The Action Plan for Rural Drinking Water Quality 2003 –2006, published by the
National Rural Water Monitoring Committee, sets out a national strategy for bringing
privately sourced group water schemes into compliance with the Drinking Water
Regulations”. The Regulations apply to all Group Water Schemes “currently providing more
than 10m3 [of water] per day or supplying a commercial or public activity” (Department of
the Environment, Heritage and Local Government 2006, p.6.). In practical terms, the 10m3 of
water per day threshold applies approximately to all Group Schemes serving greater than 15
houses or 50 persons.
There are a number of capital measures under the current Rural Water Programme, which
have no relationship to the Drinking Water Regulations. These are the New Schemes
measures as well as elements of expenditure under the Network Upgrade, Connections to the
Public Mains and Takeover measures. However, a longstanding objective of the Rural Water
Programme is to provide “a sufficient quantity of piped water in as many houses as feasible”
72
that is “of a suitable quality for drinking water” (Department of Finance 1989, p. 2.). The
2000-’06 National Development Plan (NDP) allocated €373.3m to the Rural Water Measure
in the Border Midlands West (BMW) region. It stated that “better quality water is required,
not alone for public health and quality of life reasons, but also to strengthen the infrastructure
base of the areas concerned”. The NDP allocation for the Southern and Eastern (S&E) Region
was €160m. This funding is for “upgrading quality-deficient group water schemes and
installing new group schemes”.
Terms of Reference No. 2
Examine the current validity of those objectives and their compatibility with the overall
strategy of the Department of the Environment, Heritage and Local Government.
Current validity of objectives
The best starting place for considering the current validity of the Rural Water Programme
objectives is the most recent EPA Drinking Water Quality Report published in January 2007.
The report states that quality of group water schemes has historically been inferior to that of
the public water supplies. It also states that the quality of water supplied by private group
water schemes was of an inferior status in 2005 (2007,p.42.). The section concludes that “if
the situation is allowed to continue as is at present, it is unlikely that compliance with the
drinking water Regulations is going to be achieved in the group water scheme[sic] for many
years” (ibid, p.43).
As can be seen from Table 4.02 on p.77. , implementation of the water quality upgrade
programme was only partially complete by June 2006 so further funding will be required post
2006 to complete the programme. The Minister for the Environment, Heritage and Local
Government confirmed this when allocating €142 million under the 2007 Rural Water
Programme. The Minister said that “the main emphasis in 2007 would be on measures to
eliminate water quality deficiencies in group water schemes with private sources. Many of
these schemes have been identified by the Environmental Protection Agency as failing to
meet mandatory drinking water standards” (Departmental Press Release, 1st March 2007).
Compatibility with Departmental Strategy
73
The current Strategy Statement of the Department of the Environment, Heritage and Local
Government makes several references to the issue of drinking water quality. It states that
“Significant progress has been made in meeting EU and National requirements in relation to
water quality and urban wastewater discharges and in strengthening our economic
infrastructure to facilitate industrial and residential development. There will be a continuing
need over the period 2005 – 2007 to maintain the momentum that has been built
up….Licensing will be introduced for the group water scheme sector to address ongoing
quality problems in the sector.” (p.28)
One of the Key Performance Indicators stated in the Strategy Statement is
“The delivery of high quality water supply and wastewater services to the public and industry
in accordance with objectives underpinning the Water Services Investment Programme,
including meeting the needs of social economic development, compliance with EU and
National requirements in relation to urban wastewater discharges, drinking water quality and
sludge management (p.30. KPI)”
The Strategy Statements also states
“In relation to rural water supplies, which rely heavily on voluntary group schemes, the
Department has promoted a partnership approach involving the local authorities, the
National Federation of Group Water Schemes and the National Rural Water Monitoring
Committee in order to secure necessary improvements in standards” (p.41.)
It is clear, therefore, that the current water quality objectives of the Rural Water Programme
are compatible with the current overall strategy of the Department of the Environment,
Heritage and Local Government.
74
Terms of Reference No. 3, 4 & 5

Define the outputs associated with the programme activity and identify the level
and trend of those outputs

Examine the extent that the programme’s objectives have been achieved, and
comment on the effectiveness with which they have been achieved.

Identify the level and trend of costs associated with the Action Plan for Rural
Drinking Water Quality 2003-’06 and thus comment on the efficiency with which
it has achieved its objectives.
Introduction
These above three terms of reference will be addressed together by examining the
implementation, cost efficiency and effectiveness of each of the capital spending measures in
Table 4.01 below. Firstly though, an overview will be taken of progress to date based mainly
on data collected from each local authority participating in the Rural Water Programme.
Much of this data is drawn from a Questionnaire completed by all Councils responsible for
the implementation of the Rural Water Programme (see Appendix 4). This will be followed
by a detailed examination of each water quality upgrade solution, including an analysis of a
number of case studies. Finally, a comparison will be made of the respective efficiency and
effectiveness of the different water quality upgrade solutions. The new group water schemes
and pipe network upgrade measures will also be considered as well as the annual operational
subsidy for domestic water consumers on group schemes.
Overview of programme inputs
As can be seen from Table 4.01 below, there has been a considerable degree of capital
expenditure under the Rural Water Programme between 2003 and 2006. The DBO and DBO
advance works measures have been the greatest recipients of funding by far. It is also
particularly noticeable that the second greatest capital expenditure area is not a water quality
upgrade solution at all but pipe network upgrades. This expenditure area will be examined in
detail later on in this chapter. It should be pointed out, however, that the network upgrades
75
measure also funds the disinfection/sterilisation, non-DBO water quality upgrade solutions
and the new Group Schemes measures as well.
Table 4.01 Annual Expenditure on Capital measures under the Rural Water Programme
Expenditure on Capital
Measures (€ million)
Design Build Operate (DBO)
DBO Advance Work
LA Takeover
2003
2004
2005
8.723
21.194
33.812
31.568
95.297
-
16.874
18.464
35.338
-
2006 Total
9.467
8.91
10.884
16.924
46.185
Upgrade of GWS networks
30.352
20.323
25.738
28.996
105.409
Connect to the Public Main
-
5.367
6.751
3.895
16.013
55.794
94.059
99.847
298.242
Total
48.542
Source: Department of the Environment, Heritage and Local Government
Overview of programme outputs
When the trend of annual expenditure is compared against programme outputs at June 2006 in
Table 4.02 below, it is noticeable that the DBO expenditure reflects a considerable degree of
activity under this measure in terms of schemes completed and underway. It is also the most
common water quality upgrade solution for 35% of the Group Schemes. It is also noticeable
that there has been a lower level of implementation for the two upgrade solutions involving
connection to the public mains with only 5% of schemes complete in both cases. This
implementation issue will be discussed in detail later on in the chapter. Implementation under
the disinfection/sterilisation solution is very high at 75%. However, this is because the
treatment facilities were often in place prior to the 2003-’06 period and only received minor
upgrades. There are specific issues relating to the effectiveness of this water quality upgrade
solution, which will be discussed later on in the chapter.
Finally, it is very noticeable that there is a mismatch between the expenditure inputs and
capital outputs in terms of the data available. This is because, as already mentioned, the nonDBO, disinfection/sterilisation solutions and new Group Schemes are funded from the
network upgrade measure. Also, Councils are not required to provide overall statistics to the
76
Department on new Group Schemes and completed pipe network upgrades. This is because
the Rural Water Programme is a devolved local authority function. The output data in table
4.02 below was compiled to update the European Commission on progress in meeting the
terms of the Drinking Water Directive. Local authorities were asked to provide output data for
new schemes and pipe network upgrades during the 2003-’06 period in their questionnaire
returns and this will be discussed later on in this chapter. The need for a greater match
between programme inputs and outputs will be considered in the chapter on performance
indicators.
Table 4.02
Implementation Status of Group Water Schemes by upgrade solution category
Treatment Solutions
DBO
Non-DBO
Connect to Public Main
Council Takeover
Disinfection/Sterilisation
Public Source
Total No. of Schemes
% implementation
% Solution In
Work in Upgrades Total
% Upgrades
breakdown Planning Progress Complete Schemes complete
35%
3%
16%
9%
17%
20%
100%
19
7
85
35
19
21
209
9
27
27
11
15
30
5
6
3
92
109
258
21
118
65
122
145
186
26%
298
41%
245
34%
729
12%
24%
5%
5%
75%
75%
Ref. Figures derived from June 2006 Report to the European Commission on Measures to bring Group
Water Schemes into compliance with the Drinking Water Directive
Overview of Programme Implementation
Local authorities were asked in the Questionnaire to provide estimates of the number of
Group Schemes currently participating and not participating in the Rural Water Programme
(see table 4.03 below). Councils estimated that 620 Group Schemes (77,669 houses) were
participating while 59 Schemes (4,666 houses) were not. It should be noted that this totals 679
Group Schemes in all. This differs slightly with the 729 Schemes total in Table 4.02 above
but can be explained by changes such as Group Scheme mergers etc. in the intervening
period. 36 of the non-participating schemes were receiving their annual domestic operating
subsidy while 23 schemes were not. In many cases, these 23 Group Schemes did not even
77
claim their subsidy. These figures below would suggest that the level of engagement with the
Rural Water Programme is quite good with slightly less than 10% non-participation. It must
be remembered, however, that these 10% represent the hard core of non-participants, who
want nothing to do with the water quality upgrade programme. There are in addition a number
of Group Schemes, who are co-operating with the Programme, but have not moved forward
with the implementation of their water quality upgrade solution. It is more difficult to
estimate how many Schemes fall into this category but the relatively large number of Group
Schemes still categorised as in planning in Table 4.02, particularly for the ‘Connection to the
Public Mains’ and ‘Takeover’ categories do provide a good indicator.
Table 4.03
Local Authority Estimate of Group Water Schemes’ participation in Rural Water Programme
Schemes
Participating Schemes Not Participating
No. of
No. of
Schemes Receiving
Schemes
Schemes
Subsidy
Schemes Not Receiving Subsidy
620
59
36
23
No. of Houses No. of Houses Houses Receiving Subsidy Houses Not Receiving Subsidy
77,669
4,666
3,735
931
Source: Qs. 9-10. of Local Authority Questionnaire Returns 2007
Obstacles to implementation
This invariably leads to the question of what is holding up implementation. Local authorities
offered a number of explanations in their responses to Q5 on the Questionnaire.







Non-domestic consumers on Group Schemes unwilling to be connected to the public
mains or be taken over as they would have to pay local authority water charges
Poor enforcement powers available to local authorities
Difficulties in acquiring lands and way leaves particularly where land owner is
opposing water quality upgrade solution
Reluctance of Group to accept most suitable treatment solution
Difficulty of getting 100% of members to sign application required for Council
takeover
Insufficient public water services available to connect to
Economic viability of smaller Group Water Schemes if treatment added to operational
costs
78








Fear of chlorination in the water by Group members
Groups reluctant to sign 20 year DBO Operational &Maintenance contracts
Lack of ongoing commitment of Group Schemes to maintenance
Group Schemes do not perceive that there is a water quality problem
Concerns re. future volunteerism on Group Schemes
Lack of State grants for universal metering of all Group Schemes, apart from DBOs.
Very independent Group Water Scheme Committees
Need to raise 15% capital contribution for Connection to the Public Mains (CTPM)
Councils were also asked in Q6 of the questionnaire to outline additional measures, if any,
which could improve implementation of the water quality upgrades under the Rural Water
Programme. Councils proposed a number of additional measures outlined below.









Greater enforcement powers to be made available to local authorities in Water
Services Bill
Streamline land acquisition mechanisms to expedite scheme takeovers
Additional network upgrading funding
Extension of regional water supplies suggested by Clare County Council
None -has to be by consensus as you can’t push Group Schemes – Cork South CC
Link subsidy to water quality compliance
Increase grant aid to encourage take up of grants
Source Protection Schemes are required to secure the State’s investment
An accreditation or award scheme for GWS may encourage awareness of quality
issues
It would appear that the two main issues holding up implementation of the Rural Water
Programme are the lack of appreciation that there is a water quality problem on some schemes
and an unwillingness by non-domestic water consumers to be connected to the public mains
or taken over, where this is the preferable upgrade solution. The latter issue will be discussed
in detail later on in this chapter in the public source solution section. Councils were
empowered to take prosecutions against non-compliant Group Schemes under the 2000
Drinking Water Regulations, however the 2007 EPA Drinking Water Report found no
evidence of any such prosecutions taken in 2005. One member of a Group Scheme can
currently veto a Scheme’s takeover by its local authority as this requires 100% membership
agreement. The delays in the enactment of the Water Services Bill meant that the power to
allow Councils to take over Group Schemes with the two thirds agreement of its members had
been delayed.
79
It should be noted, however, that there are existing provisions under Sections 6 and 8 of the
Local Government (Sanitary Services) Act 1962 and Section 79 of the Public Health (Ireland)
Act 1878, which empower local authorities to take remedial action in relation to poor quality
water supplies (Department of Finance 1989, p.54.). These legal provisions are in force until
commencement of relevant sections of the Water Services Act supercedes them. On 13th
March 2007, the Minister for the Environment, Heritage and Local Government approved
revised Drinking Water Regulations (S.I. No. 106 of 2007), which gives Councils additional
powers to carry out remedial water quality upgrade works on Group Schemes, without
members’ consent if necessary (Section 12[2]).
Effectiveness of Rural Water Programme
Local authorities were asked in Q12 of their questionnaire returns to provide details of any
completed Group schemes that are still non-compliant with the Drinking Water Directive after
upgrading (see Table 4.04 below). Seven Councils reported that 16 Group Schemes overall
were non-compliant after upgrading. 16 schemes non-compliant out of 245 complete (as per
Table 4.01) i.e. less than 7% does not appear to be too high. However, the evidence of case
studies later on in this chapter would suggest that Councils under reported the rate of noncompliance post upgrading in their Questionnaire returns. As already explained in Chapter 3
(Review Methodology), these case studies include a sample of upgraded Group Schemes for
all solutions with EPA and local authority water quality test results being used to verify
compliance.
Table 4.04 – Non-Compliant Schemes after upgrading
No. of
No. of
County Council Schemes Houses
Reasons for water quality test failure/Risk Factors
80
Cork North
Cork South
Galway
Kilkenny
Offaly
Sligo
Wexford
1
1
11
No figures
provided
No figures
provided
32 Unknown
62 Inadequate pipe network maintenance
1,641 Inadequate plant monitoring and pipe network maintenance
No figures Inadequate O&M of plant chlorinator. Problem with nitrates
provided and septic tanks contaminating borehole sources
No figures
provided Nitrates
2
1
a major risk factor
Inadequate scouring of pipelines
3 Includes pub connection. Lack of O&M of Group Scheme
16
1,750
Total
Source: Q12 - Compliance status after completion of water quality upgrade
The Councils do not specify the upgrading solutions used in the cases of the non-compliant
schemes above. However, inadequate treatment maintenance, pipe network maintenance and
source protection appear to be common themes. All of these issues will be considered further
in the course of this study. Non-compliance, due to inadequate treatment maintenance by
Group Schemes, would indicate the use of the Disinfection/Sterilisation and Non-DBO
solutions as these are the only solutions, where Group scheme volunteers retain responsibility
for the operation of the water treatment infrastructure. There will be a particular focus on the
effectiveness of these water upgrade solutions later on in this chapter. All Councils confirmed
in Q11 of their questionnaire returns that they carry out water quality testing on Group Water
Schemes in compliance with their statutory requirements under the Drinking Water
Regulations. One Council did admit to reducing testing to twice per year due to lack of
resources. The 2007 EPA Drinking Water Report stated that the level of water quality
monitoring was inadequate in several Councils. The Minister for the Environment, Heritage
and Local Government has given the EPA greater powers, under the 2007 Drinking Water
Regulations, to take enforcement action against Councils, which do not comply with their
statutory water quality monitoring duties. The effectiveness of all water quality upgrading
solutions will be assessed later on in this chapter using 2005 EPA water quality data and local
authority information for a selection of Group Schemes upgraded since 2003.
Efficiency of the Rural Water Programme
All Councils were asked to confirm in the Questionnaire whether they had adopted the most
economically advantageous available water quality upgrade solution for Group schemes in
81
their administrative area (Q.1). They were also asked to confirm that they had considered and
costed all alternative options and most specifically standalone DBO plants versus connecting
Group Schemes to the public mains (Q.2).
Table 4.05 - Councils’ responses to cost efficiency issues in Questionnaire
Carlow
Cavan
Clare
Cork North
Cork South
Cork West
Donegal
Galway
Kerry
Kildare
Kilkenny
Laois
Leitrim
Limerick
Longford
Louth
Mayo
Meath
Monaghan
Nth Tipp
Offaly
Roscommon
Sligo
South Tipp
Waterford
Westmeath
Wexford
Wicklow
Q1
Q2
Q3
Q4
Cheapest
option
selected
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Costed
all
options
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
No
Yes
No
Yes
Yes
No
Yes
No
No
Yes
Yes
Competitive DBO SubTenders
bundling
used
considered
Yes
Yes
Yes
No
Yes
No
Yes
N/A
Yes
N/A
Yes
N/A
Yes
N/A
Yes
Yes
Yes
N/A
Yes
Yes
Yes
N/A
Yes
Yes
Yes
Yes
Yes
No
Yes
N/A
Yes
N/A
Yes
Yes
Yes
No
Yes
Yes
Yes
N/A
Yes
N/A
Yes
Yes
Yes
No
Yes
N/A
Yes
N/A
Yes
N/A
Yes
Yes
Yes
Yes
Sources: Responses to Local Authority Questionnaire- December 2006
Councils were requested to confirm that competitive tendering had been used to procure
contractors to carry out the water quality upgrade works required (Q3). If a DBO treatment
plant was the chosen water quality upgrade solution, Councils were asked whether the sub-
82
bundling of DBO contracts, so that one treatment plant could serve two or more Group Water
Schemes, was considered (Q4).
Councils responses to these four questions are set out in Table 4.05 above. All Councils, with
the exception of Meath, responded that they had implemented the most cost efficient solution
for their Group Schemes (Q1). Meath County Council stated that one of their Group Schemes
refused to be connected to the public water supply and insisted on using their own private
source. Most Councils confirmed that they had carried out a comparison of the relative cost of
building a DBO treatment plant to connecting their Group Schemes to the public mains (Q2).
Councils were asked to provide documentary supporting this but few Councils provided this
information within the timeframe of this Review. It will be recommended in the DBO section
that this information be provided as part of the final accounts for the DBO treatment plant
projects, in the interests of transparency. In cases where no cost comparison was carried out,
Councils explained that this was because;

Group Schemes were too far from the public mains for connection to be technically or
economically feasible

There was insufficient water supply capacity at the nearest public water treatment
plant

Group Schemes were unwilling to be connected to the public mains
Building additional treatment capacity at the nearest public treatment plant does not appear to
have been considered as an option. All Group Schemes confirmed that competitive tendering
was used to procure contractors to carry out the water quality upgrade works (Q3). Councils
were also asked about measures taken to ensure that treatment plant design capacities were
economical with limited allowance for unaccounted for water (Q14-16). In nearly all cases,
Councils responded that they had designed treatment plants in compliance with the
Department’s guidelines that “water treatment plant capacity should be capped at current
demand levels, plus an allowance in respect of projected growth demand over a 20 years
horizon, plus an allowance of 25% for unaccounted for water (Departmental Circular
L11/2004).
83
There was a mixed response to the question of whether the sub-bundling of two or more
Group Schemes for connection to the same treatment plant was considered (Q4). It was
considered on the newer DBO bundles e.g. Galway and Mayo DBO Bundles No. 2 as well as
the inter-county South Leinster DBO. The reasons why sub-bundling was not adopted in some
counties were;

Some Group Schemes had already merged prior to DBO contracts being developed
and were served by one DBO treatment plant e.g. Erne Valley DBO in South West
Cavan DBO.

Not economically feasible due to geographical distance between Group Schemes

No water source with adequate capacity to serve larger sub-bundled DBO treament
plant
Criteria for upgrade solution selection
There appears to be a slight element of ambiguity in relation to the basis for determining
which water quality upgrade solution should be adopted. The Rural Water Strategic Plan
Guidance document advises Councils to carry out an analysis of various solutions in order to
identify the ‘most economically advantageous’ approach. Departmental Circular (L4/98),
which established most of the structures of the existing Rural Water Programme, emphasises
the importance of a partnership approach between local authorities and the Group Schemes’
sector in the determination and implementation of rural water policy. It is not 100% clear,
who ultimately decides what the upgrade solution route should be, the local authority or the
Group Water Scheme. The National Federation of Group Water Schemes (NFGWS) were
asked for their understanding of this. They responded that in cases where the cost difference
between different solution options is ‘marginal’, it should be a matter for the Group Water
Schemes themselves to decide. The Federation also commented that agreeing treatment
solutions by consensus rather than imposing solutions on Group Schemes is the preferable
route. This interpretation concurs with the understanding of Departmental technical staff on
the issue.
This appears to be a pragmatic and sensible approach to take when dealing with the privately
owned and voluntarily run Group Schemes sector, where the cost difference is marginal.
However, it is clear that in certain cases, Group Schemes are unwilling to be connected to the
84
public mains because of non-domestic water charges and are seeking instead to have an often
more expensive DBO treatment plant built. There are indications that some local authorities
may have agreed to this in a small number of cases. Other Councils are not permitting this on
cost grounds with the result that some Group Schemes are resisting connection to the public
main or local authority takeover. It is impossible to form a definitive view without
documentary verification from Councils that an analysis of the various cost options was
carried out in each case. In many cases, however, Group Schemes were too geographically
distant from public mains for connection to be a practical option or the raw water chemistry
was not of sufficiently high standard for disinfection/sterilisation to be an option. Therefore,
there was no option but to build a DBO water treatment plant either as a standalone or serving
several adjacent Group Schemes, where technically possible. It is important, however, that
the Department reminds Councils that while a partnership approach with the Group Schemes’
sector is vital for programme implementation, the ‘most economically advantageous’
treatment approach must ultimately be adopted in the interests of the taxpayer.
Conclusions
Many of these issues will be considered in far more detail in the following section of the
chapter, which considers the implementation, efficiency and effectiveness of each of the water
quality upgrade solutions separately. Some comparisons between water quality upgrade
solutions are also done at the end of the chapter. Expenditure on non-water quality related
upgrade measures such as pipe network upgrades, new schemes and the annual operational
domestic subsidy will also be reviewed separately.
85
Design Build Operate (DBO) Water Quality Upgrade Solution
Introduction
This is the water quality upgrade that has been identified for 258 of the 729 schemes (35%). It
also constitutes the single largest investment of all the other water treatment upgrade solutions
put together with an investment of €130 million over the 2003-’06 period, with €95m on DBO
works and €35m on Advance DBO works. This constitutes 44% of all capital expenditure on
the Group Schemes sector during 2003-’06 and 68% of all capital expenditure on water
quality upgrade solutions only i.e. excluding new Group Schemes and pipe network upgrade
expenditure. The Design Build Operate (DBO) Bundle approach is quite complex so it is
appropriate to explain its operation in some detail before the specific issues of efficiency and
effectiveness are addressed.
Development of DBOs
Under traditional procurement, the design, build and operation of a water treatment plant is a
separate three stage process. A project consultant is engaged who plans and designs the
treatment plant. The plant specification is then put out to tender and a contractor is engaged to
build the plant. Once the treatment plant has been completed and commissioned, the
contractor transfers responsibility for the treatment plant to an operator, traditionally local
authority technical staff. This traditional three stage approach was regarded as having several
shortcomings. Firstly, in designing the treatment plant, the project consultant has little
incentive to produce the most cost efficient construction design. By combining the design and
build of the plant into one contract, contractors are incentivised to produce the most cost
efficient plant design if they are to win the contract. There were a small number of pilot
Design Build (DB) projects constructed prior to the 2003-’06 period under review. However,
problems were encountered with their operation and maintenance after they were
commissioned (NRWMC 2005, p.4.). Basically, while contractors were building plants that
met the necessary specifications they were not efficient and effective from an operation and
maintenance perspective.
The concept of DBO was then developed firstly on the public schemes side and then in the
Group Schemes’ sector. Successful contractors would not just design and operate the
86
treatment plants but would also operate and maintain the plants over a 20 year time period. 20
years is regarded as the most appropriate O&M period as it coincides with the expected life
cycle of the treatment plant and it allows the DBO operator to recover their costs, which are
usually significantly frontloaded at the start of the project. This was regarded as the most cost
efficient and effective approach as the contractor in bidding knew that they would have to
design and construct a plant that could be run in a cost efficient manner over its design life
cycle. It also had the benefit of providing transparency in relation to the full life cost of
operating the treatment plant allowing tenders to be assessed on a net present value basis
(NPV) using a 5% discount rate in accordance with Department of Finance guidelines (2005).
DBOs contracts also transfer a considerable amount of financial risk to the contractor. Under
traditional procurement, unforeseen costs such drilling through rock etc. was generally borne
by the client through price variation clauses in the contract. Under DBO contracts, there is
very little scope for the contractor to claim for extra costs so invariably a greater degree of
risk is carried.
It must be emphasised that the use of DBOs should not be interpreted as a policy preference in
favour of the public private partnership (PPP) approach. The Department does not regard
Group Scheme DBO plants as being PPP projects and as such the public sector benchmark
was not applied. DBOs are regarded as the most appropriate procurement approach for Group
Schemes given that the newly constructed water treatment plants are transferred to private
Group Scheme rather than local authority ownership post construction. Council personnel
have no role in the operation of these plants so it is necessary to have a professional operator
in place as Group Scheme volunteers would not be qualified to carry out this role. Also,
although the State provides most of the capital funding for the design and build of these
plants, the operation and maintenance costs have to be paid by the Group Scheme members
apart from the annual subsidy payment for the domestic operation and maintenance cost
element.
87
Cost Breakdown of a DBO for a water treatment plant
The various capital and operational and maintenance cost elements of DBO treatment plants
are set out below. Much of this detail has been extracted from the Department’s “Guidance
Document for the Procurement of Small Water Services, Part C” (2002, p.70-72):
Capital Costs
The capital costs are broken down into
(i) civil engineering and building – the building housing the treatment plant along with rising
mains and reservoirs.
(ii) Mechanical and Electrical – the actual infrastructure used to treat the water
Operation and Maintenance Costs
1. Fixed Time based charges for the operation of the works(€/month). This includes the
cost of appropriate labour, routine prevention maintenance, sampling and testing,
insurance, updating management and quality plans, reporting procedures, supervision,
management etc.
2. Fixed time based charges for the maintenance of the works (€/month). This includes
scheduled maintenance and refurbishment of plant and buildings including
replacement of parts having an expected useful life of not more than five years.
3. A volumetric charge payable to the contractor based on the production of the treated
water incl. chemicals and energy costs directly related to the volume of water treated
(€ / m3 )
Capital Replacement Fund
The Group Scheme trustees, who are formally referred to as the employer in the DBO
contract with the DBO operator, must pay funds into a bank account for the replacement of
items of plant with a design life of more than 5 years. These could include “items such as
bearings, drive belts on pumps and electrical motors as well as control and automation
equipment” (ibid, p.8.). These costs are an integral part of the O&M portion of the contract.
There should be a standard monthly charge to accumulate the required funds in a bank
88
account at the end of each of the five year periods comprising the total 20 year O&M period.
There are separate charges for each of the five year periods with charges for individual years
for the last 5 years to facilitate flexibility during handover.
Discounting and Net Present value
The fixed time and volumetric charges are discounted over the contract lifetime using a 5%
discount rate as per the Department of Finance. While the volumetric charge will vary over
the lifetime of the contract, the estimated current consumption is used for the purposes of
tender evaluation. It is expected that future increases in consumption demand, due to new
developments, will be offset by water conservation measures and reduced consumption by
non-domestic users. There will also be an index linked fluctuation clause to allow for
inflation. The estimated breakdown between fixed and volumetric costs, over the lifetime of
the DBO project, is set out in Table 4.1.1 below.
Table 4.1.1 -Indicative breakdown of O&M costs for water treatment
Category
Elements
% of Total
Costs
Fixed – time based (incl.
Labour, transport, head-office overheads,
CRF)
management
Variable – Volumetric
Cost per m3 of water includes chemicals,
60%-85%
15%-40%
pumping and other electrical costs
Source: Procurement Guidance Document 2002 p.8.
DBO Grant structure
The Department grant aids the capital cost of DBO treatment plants up to a maximum of
€6,476 per house in the Group Scheme being served by the plant. This includes 100% of the
cost of mechanical and electrical contract i.e. the treatment infrastructure itself. The
Department funds 85% of the civil works contract with a 15% contribution from the Group
Scheme members. The civil works contract would generally include elements such as the
building containing the treatment infrastructure, reservoirs, rising mains and the access road
to the plant. Any interconnector pipes to connect more than one scheme to the same treatment
plant is funded at 100%. In addition, any pipe network upgrades to reduce Unaccounted for
89
Water (UFW) and avoid pipe recontamination is funded by a second 85% capital grant also up
to a maximum of €6,476 per house. This second grant can be claimed from the network
upgrade capital measure. Finally, Group Schemes can recoup an annual subsidy from the
Department for the domestic household element of their operation and maintenance costs up
to a maximum of €196.81 per house per year. This DBO subsidy limit is almost twice that of
the normal subsidy limit of €101.58 in recognition of the additional costs for domestic
households involved in funding the professional operation and maintenance of DBO treatment
plants.
The overall grant cap of €6,476 per house and 15% contribution from Group Schemes for
civil works is an important cost control safeguard as it removes the incentive for Group
Schemes to ‘gold plate’ their treatment plants with unnecessary expenditure as they will have
to contribute towards the costs. The capital grant limits also reduces the incentive for DBO
operators and Group Schemes to over engineer the treatment plants at the State’s expense so
that subsequent operation and maintenance costs can be minimised. Similarly, the 85% grant
limit on pipe network upgrades reduces the incentive for Group Schemes to have unnecessary
pipe network replacement.
Evolution of DBO bundles
Although the above grant limits are relatively generous by comparison to the new Scottish
grant system discussed in the Literature Review [€1,178 per house], they do create cost
pressures in viably financing water treatment plants serving relatively small populations. As
can be seen from the Fitzpatrick Report, bigger projects tend to generate economies of scale
thus reducing costs (2005,p.44.). It would have proved prohibitively expensive to individually
procure a DBO plant for each Group Scheme within existing grant limits and indeed it would
have been impossible in many cases. The Department was aware that the small size of the
Irish market meant that there were a limited number of construction firms available to carry
out this kind of work. It was also known that advances had been made in small treatment plant
technologies in other countries, which were not available in the Irish marketplace. Therefore,
it was decided to procure a number of DBO treatment plants as a single package known as a
DBO bundle. In this way, international consortia would be attracted to bid for these projects
on the basis that they would gain a large volume of work if successful. A larger number of
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bundled schemes should create economies of scale and reduce unit cost. For this reason, the
DBO bundle is considered to be a cost effective solution.
In the Department’s procurement guidance, it is advised, to achieve critical mass, that there
should be a sufficient number of schemes in a DBO bundle so that the services of two or more
operations staff are required on a full-time basis. This removes an element of redundancy,
which could unnecessarily inflate the service providers’ costs. On the other hand, because of
the time constraints in terms of getting plants into operation due to water quality problems, an
upper limit of 20 bundled schemes was suggested. This could be increased where the nature
of the scheme would allow the contractor to complete the work within a reasonable period
(2002, pp.8-9.). Because of the complex nature of these contracts, local authorities would act
as employers during the design and construction phase of the project and then withdraw
following scheme completion. The participating Group Schemes will then take over as DBO
employers and deal directly with the DBO service provider during the operation and
maintenance (O&M) phase of the DBO contract (ibid, pp.9-10.).
Technical advisors known as Client Representatives were to be engaged (by competitive
procurement) to prepare the DBO bundle tender documents and assess the tender bids. They
would also oversee the Design/Build of the project on behalf of both the Council and Group
Schemes in the DBO bundle. The Client Representative for a DBO bundle would also ensure
that planning, land ownership and access arrangements are legally in place before a particular
scheme is allowed to enter the DBO bundle. To date, four firms of consulting engineers have
been engaged as client representatives and four DBO consortia have been awarded all DBO
bundle contracts either underway or complete to date (see Table 4.1.2 below). It should be
noted, from above, that DBO Client Representatives and DBO contractors are procured
separately so the Client Rep./Contractor combination differs in many DBO bundles.
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Table 4.1.2 – List of DBO Client Representatives and DBO contractors
DBO Client Representatives
DBO Contract Consortia
Jennings&O’Donovan & Partners (JOD)
EarthTech Ireland Ltd. (ETIL)
Ryan Hanley (RH)
Electrical and Pump Services ( EPS )
T J O’Connor & Associates (TJOC)
Treatment Systems Services Ltd. ( TSSL )
P J Tobin
Veolia
DBO Solution Implementation and overall expenditure
As previously stated, implementation under the DBO treatment solution was very advanced in
June 2006 with 12% of schemes complete and 81% underway. By April 2007, 11 DBO
Bundles in seven counties were completed or nearing completion with treatment plants in
place for 101 Group Water Schemes (see Table 4.1.3 below). Work is currently underway on
the South Leinster DBO Bundle covering six counties. Mayo No. 2 and Galway No. 2 DBO
Bundles have recently gone to tender.
Table 4.1.3 - Completed DBO Group Water Scheme Bundles – April 2007 (see also Appendix 7)
County
Bundle Name
Provisional Average DB
Clients No. of No. of Total Design Cost per
Contractor Rep
GWS Houses Build Cost (€) House (€)
Cavan
Cavan
Cavan
Clare
Monaghan
Sligo
Sligo
Mayo
Galway
Galway
Limerick
Cavan West
Cavan East
Cavan South West
Clare Bundle
Monaghan Bundle
Sligo North West
Sligo South East
Mayo No. 1
Glynsk/Creggs
Galway Bundle 1
Limerick Bundle
EPS
Veolia
EPS
EPS
Veolia
TSSL
TSSL
Earthtech
Veolia
TSSL
EPS
1,405
3,393
1,815
2,840
3,991
668
1,291
4,125
320
2,953
2,513
€7,101,151
€7,284,812
€4,023,583
€6,417,217
€7,846,228
€1,825,729
€2,616,622
€8,255,073
€977,130
€7,844,505
€4,794,256
101 25,314
€58,986,307
JOD
TJOC
Tobin
JOD
TJOC
TJOC
JOD
RH
TJOC
RH
TJOC
Totals
9
10
5
4
14
6
5
14
1
15
18
Source: DBO Clients Representatives and Local Authorities
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€5,054
€2,147
€2,217
€2,260
€1,966
€2,733
€2,027
€2,001
€3,054
€2,656
€1,908
Efficiency of DBO Solution
As such a significant level of investment is being made under the DBO upgrade solution, all
11 completed DBO bundles were evaluated. Data was collected from both the local
authorities and client representatives overseeing the projects on behalf of the Councils and
Group Scheme members. However, it must be stressed that the financial data provided in
Table 4.1.3 above is provisional and may be considerably understated. This is because
final accounts have not been prepared on any of the completed DBO yet as they were mainly
only completed from mid 2006 onwards. There could be additional costs such as advance
DBO works, which will need to be incorporated into the final figures. Also, some DBO
scheme data is likely to be more comprehensive than the data for other DBO schemes so
definitive cost comparisons cannot be made until all figures are finalised. For example, the
data provided on the number of houses in the Monaghan DBO is incomplete. Financial data
for follow on pipe network upgrades are also not available yet. These figures are necessary to
calculate the full cost of bringing the above Group Water Schemes into compliance with the
Drinking Water Regulations. The additional figures are also necessary to draw an accurate
comparison with the cost of alternative water quality upgrade solutions e.g. Council
Takeovers etc. Therefore, all the data in Table 4.1.3 above may be subject to revision after
the respective local authorities prepare final accounts.
Unit Cost Analysis
It would be unwieldy for presentational purposes to provide provisional design build cost data
for all 101 completed Group Water Scheme DBO projects in the body of the text. Therefore,
the provisional data is summarised on a DBO Bundle basis in Table 4.1.3. Provisional design
build (DB) cost data for each completed Group Water Scheme is provided in Appendix 7. An
average DB cost per house has been calculated for each bundle by dividing the Total DB cost
of all Schemes in the Bundle by the total number of houses in the Bundle. These average DB
costs per house are presented in the last column of Table 4.1.3 above. As can be seen, they
vary widely from €1,908 per house in Limerick up to €5,054 per house in Cavan West. It
would be unwise to draw any conclusions as to why there is such a marked difference in the
average DB cost per house for these two bundles in the absence of definitive and complete
final accounts figures for both DBO bundles. In the final analysis, it may just prove to be an
93
illustration of the hazards of using the unit cost approach is trying to compare the relative
costs of two very different water treatment projects.
Other measures of efficiency
In an area as complex as the construction of DBO Treatment Plants, there are several areas
where efficiency has to be considered. Because of the bespoke nature of treatment plants
serving widely varying population patterns, it is difficult to compare capital costs on a unit
cost basis. Other efficiency issues must also be considered.

Were alternative more cost efficient options to DBO treatment plants explored

Was there competitive procurement

Was the option of connecting more than one plant to the treatment plant considered

Was the most economic plant capacity used
Consideration of alternative water quality upgrade options
Given the expense of building a water treatment plant, DBO client representatives and local
authorities were asked whether this was the only upgrade option considered. Specifically, was
the option of connecting these Group Schemes to the public mains (CTPM) considered and
costed. In most cases, Client Reps said that the CTPM option was considered. The reasons
given for turning down the option were that

schemes were too far from the public mains so it was too expensive

the pipe network at the extremities of the existing public networks were too small to
be connected into Group Schemes

there was insufficient existing capacity on public treatment plants
It noticeable that consideration was not given to costing the option of increasing treatment
plant capacity on existing public plants, where connection was a viable technical and financial
option. It is not clear whether such capital funding could come from the Rural Water
Programme or the main Public Schemes Investment Programme. This could indicate a need
for greater harmonisation between the two investment programmes. Councils were asked to
provide documentation verifying that CTPM was considered and costed as the most
economically advantageous option as specified in the Rural Water Strategic Plan Guidance
94
documentation. Very few Councils provided this verification within the timeframe of this
Review. There is evidence in at least 4 cases that Group Schemes refused the more economic
CTPM option and insisted on a treatment plant instead. That said, in most cases it appears that
the construction of a water treatment plant was the only viable technical and economic
upgrading option.
Competitive procurement
The DBO clients have confirmed that there was competitive procurement involving several
bidders for each of the completed DBO Bundle contracts. This process was carried out in
accordance with the stringent procurement arrangements already outlined in this Chapter.
Rationalisation of Treatment Plants
It has already been established that in most cases, alternative options to constructing a
standalone DBO treatment plant were considered prior to the decision to adopt that water
quality upgrade solution. The next question is whether, the option of connecting more than
one Group Scheme to the same treatment plant was considered. This would involve additional
costs in relation to the length of pipework connection but could it, in some cases, be more
economic than building a standalone treatment plant for each Group Scheme. The evidence is
that this has happened in a few cases but generally not. It has happened in a few cases e.g. in
all three of the Cavan bundles, where the grant limit of €6,476 per house in some of the
smaller schemes and the potential size of Group members’ 15% contribution meant that a
standalone treatment plant was unviable. In some of these cases, neighbouring Group
Schemes merged to form a new Group Scheme operating off one treatment plant. An
example of this was Garty Lough and Bruskey/Killydoon in the South West Cavan DBO,
which merged to form the Erne Valley Group Scheme. That said in most of the DBO bundles,
if a stand alone DBO treatment plant could be built within existing grant limits with a
relatively affordable group contribution, that is what happened. It should borne in mind
though that while there may have been other cases where treatment plants could have been
shared to the benefit of the exchequer, the distance between Group Schemes would have made
it economically unviable in many other cases. The absence of economic assessments makes
this impossible to tell.
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The concept of rationalisation of plants is now very much on the agenda with two new DBO
bundles currently in planning i.e. Galway and Mayo Bundles No. 2. The small size of the
Group Schemes i.e. number of houses in these bundles makes a standalone DBO plant for
each Group Scheme prohibitively expensive for the Group Scheme members. Before further
discussion, it is important to first make a distinction between the concept of a bundle and a
sub-bundle. The Group Schemes in a DBO bundle have no physical or legal relationship to
one another. Their only linkage is that their treatment works is being procured as part of an
overall package of treatment plants to be built by the same contractor and overseen by the
same client representative. A sub-bundle, on the other hand, is a number of group schemes
e.g. 2 or 3 within an overall bundle, which will be physically connected to the same treatment
plant and will be legally required to join together in a new entity for the purposes of dealing
with the DBO operator over the life of the treatment plant. This rationalisation of treatment
plants involves additional interconnecting pipework, which the Department 100% funds
although the overall scheme cost divided by the number of houses in the new merged scheme
still cannot cost more than €6,476 per house. An illustration of a DBO sub-bundle with 3
Group Schemes, interconnected into one DBO treatment plant, is provided below.
Source: Ryan Hanley Consulting Engineers- Galway DBO Bundle No. 2 – Source Rationalisation Report
96
Ryan Hanley consultants carried out two extensive rationalisation studies of both of the new
bundles and compared the cost of standalone plants and sub-bundling of plants. In the case of
Mayo Bundle No. 2, Ryan Hanley proposed the provision of 12 water treatment plants to
serve the water needs of 25 Group Schemes with 7 of the proposed plants being shared. This
was estimated to be a saving of 22% or €4.3 million to the exchequer, including the cost of
100% funding inter-connector pipes, over the option of building standalone treatment plants
for each Group Scheme in the bundle (Executive Summary, August 2005).
Ryan Hanley proposed an even more sophisticated rationalisation solution in the case of
Galway DBO Bundle No. 2 . Group Schemes in Galway are particularly dependent on
groundwater, which means that there are a large number of relatively small schemes with less
than 50 domestic connections per scheme. Ryan Hanley proposed that 35 out of the 58 Group
Schemes in the DBO bundle should be rationalised into sub-bundles served by 11 DBO
treatment plants with a saving of €7.5 million to the exchequer. However, even with the
rationalisation down to 11 DBO treatment plants, the cost per house of the treatment plants in
some of the sub-bundles would well exceed the €6,476 per house grant limit because of the
small size of the schemes. This would mean that several of the smaller schemes in the 11 subbundles would not be able to afford to participate as the contribution per house could be up to
€7,000 per house in some cases. Ryan Hanley proposed as a one off solution that all 35 Group
Schemes being rationalised be treated as a single entity (sub-bundle), instead of the normal 11
entities (sub-bundles) for each of the 11 treatment plants. This formula would allow the DBO
Bundle to proceed as the cost per house of the 11 treatment plants divided by the total number
of houses in the 35 Group Schemes would be within the €6,476 per house grant limit. In this
scenario, the larger Group Schemes’ contribution would effectively subsidise the smaller
schemes. All 35 Group Schemes would have to agree to merge into one legal entity to allow
this to occur (p.4., February 2006). The Department considered this proposal and approved it
on a once off basis as Galway DBO Bundle No. 2 could proceed without having to breach
grant limits.
It could be argued that an opportunity to make additional cost savings was lost by not carrying
out an extensive rationalisation study on all the completed DBO bundles at their planning
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stage. It must be recognised though that the use of DBO bundling in the Group Scheme sector
was a completely new development and as such there was a steep learning curve involved for
the Department and local authorities. On balance then, it is fairer to acknowledge the
innovation and ingenuity involved in developing rationalisation models than in speculating on
lost opportunities with 20/20 hindsight. One issue that these developments do highlight is the
impact of the €6,476 grant ceilings and the 15% Group Scheme contribution on seeking value
for money solutions. Rationalisation was driven by the cost implications for Group Scheme
members of building stand alone treatment plants.
Plant Capacity and UFW
Departmental policy is that plant capacity for DBO treatment plants should be theoretical
design demand for the no. of houses + future development needs to 2020+25% allowance for
Unaccounted for Water (Circular L11/2004). In designing plant capacity, an allowance was
made for the water needs of each connection and the total of these was the plant water
treatment capacity required in order to meet water needs. As the plant has a 20 year design
life, an additional capacity was built in to allow for future development demand based on
population predictions. In addition to that, a 25% allowance is made for unaccounted for
water, known as UFW, which is water that will leave the treatment plant but will not reach the
consumers’ homes due to leakages in the pipe network. 25% UFW may seem like a generous
allowance but UFW is a major problem in public as well as Group Scheme pipe networks.
The Dublin Water study in the late 1990s calculated that 40% of treated water in some areas
of Dublin was lost due to leakages in the pipe (Circular L7/96). Subsequently, an extensive
National Water Conservation programme was launched to address this issue on public water
schemes.
As can be seen from Table 4.1.4 below, UFW is a substantial issue for Group Water Schemes.
The majority of Group Schemes in four completed DBO bundles shown below were
estimated to have UFW levels in excess of 25%. This creates a problem of security of water
supply for Group Schemes with treatment plant capacities based on a 25% UFW allowance.
Client Reps have reported in some cases that water treatment plants are only able to supply
sufficient water because of the additional future development capacity built in, which is not
sustainable.
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Table 4.1.4 Estimated Unaccounted for Water (UFW) in DBO Bundles
East Cavan DBO
Estimated
Estimated
UFW in
UFW in
2002 (%)
Limerick DBO
2004 (%)
Billis Lavey
54%
Baggottstown
24%
Bunnoe
44%
Ballinvreena
43%
Dhuish
35%
Ballybricken
25%
Drumkeery
41%
Ballyduff
28%
Kill
53%
Ballyorgan
23%
Mountain Lodge
19%
Bulgaden
29%
Caherline/Newtown
35%
6%
Cappagh
49%
_
Carnane
35%
Coshma/Killeen
59%
Croagh/Farradonnelly
37%
2004 UFW
Glenroe
72%
Ardrahan
29%
Glenstal
53%
Ballyglass/Fiddane
50%
Granagh
27%
Brierfield
69%
Griston
26%
Caherlistrane
66%
Kileedy
32%
_
Kilfinny
40%
Lough Gur
38%
Crosserlough
Clifferna
Dernakesh
Glaslough Tyholland
Galway DBO
Cleggan/Claddaghduff
_
34%
Cloonatleva
56%
Cloonluane
32%
Inis Meain
40%
West Cavan DBO
Kiltevna
45%
Glangevlin
13%
Doobally
32%
Toberowen Lissybroder
_
Est. UFW
Lettergesh
67%
Ballymagovern
58%
Lowville
51%
Corlough
44%
Milltown
60%
Sralaghan
37%
New Inn
38%
Kildallan
41%
Rinn Killeeneen
63%
Milltown
73%
Gowlan
44%
Source: DBO Client Representatives-January 2007
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There are two options to address this UFW issue;
1) Build treatment plants to allow for existing UFW levels
2) Implement active leakage control and water conservation measures, including pipe
network upgrades
The first option will involve the additional expense of building extra treatment plant capacity
and the additional operating costs of treating more water, much of which will be lost in the
pipe network as UFW. There is an additional environmental cost of abstracting more water
than is needed from surface or groundwater sources, which could also affect security of
supply, particularly during dry periods. The alternative option is to repair and in some cases
replace inadequate pipe networks. The question is which is the most economic solution. As
already discussed in the Literature Review, Ryan Hanley consultants carried out a Leakage
Control Study of the 21 Group Water Schemes proposed for the Mayo DBO Bundle No. 2
(currently in planning) in March 2005. The study found that it was cheaper to build additional
treatment capacity in only two of those schemes. A previous Leakage Control Study carried
out by Ryan Hanley for Galway Bundle No. 2 in August 2004 also concluded that in most
cases leakage control measures were more cost effective than building additional treatment
capacity (p.1.).
These leakage control studies reinforced the Department’s policy view that treatment plants
should only be built with a maximum UFW allowance of 25%. It was accepted, however, that
in many cases that pipe upgrade works could not wait until after completion of DBO contracts
as there was a high risk that insufficient water supply would reach households. Therefore, the
Department authorised certain critical network upgrade works be carried out as DBO
Advance Works prior to the DBO contracts to bring UFW down to relatively acceptable
levels. The issue of pipe network upgrades will be addressed later on in this chapter in the
context of all the other water quality upgrade solutions and the additional costs involved in
network upgrades to bring all Group schemes into compliance with the Drinking Water
Regulations.
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Other efficiency innovations during the DBO bundle period
Change of planning arrangements
Procurement is a vital component of the DBO process. It takes place in two stages with initial
preliminary contract bids and subsequent shortlisting of preferred bidders. The 1997 Strategic
Review of the Construction Industry (The Barry report) recommended that two stage selective
tendering be used for all DBO projects for two reasons: requisite experience and cost of
tendering (Procurement Guidance Document 2002, p.32.). It would be prohibitive on cost
grounds to ask all bidding contractors to complete full tender documentation, when only a
small number of bidders have a realistic chance of winning the contract. Therefore, a number
of initial bidders are shortlisted and invited to submit full tender documents. One significant
cost issue remained which was the issue of pre-tender planning.
Under partnership arrangements between local authorities and group schemes, planning
approval was sought by the local authority in respect of any Specified Development as set out
in Article 80, Part 8 of the Planning and Development Regulations 2001. Part 8 Planning was
usually sought at pre-tender stage.
“Pre-tender planning has, however, tended to restrict the ability of tenderers to put forward
DBO proposals that fully comply with performance specifications, while at the same time
reflecting best value for money principles. This is, in large part, due to the requirement to
comply with planning approvals already secured and overly prescriptive contract documents,
particularly for civil works. As a consequence, it is possible for the most economically
advantageous tender to be deemed non-compliant where it includes a structure or works not
specifically identified in the Part 8 Planning process. This has obvious affordability
implications for group water schemes participating in bundled DBO projects where they are
required to meet at least 15% of civil works contract costs from their own resources.”
(Circular L4/04 – 16th February 2004)
The Department of the Environment, Heritage and Local Government, therefore, decided that
the statutory planning process for DBO works would no longer be completed prior to the
issue of contract documents.
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“Instead, each tenderer will now be required to provide, as part of the Contractor’s Proposal:
(a) the appropriate planning documentation the Contracting Authority would need to initiate
the Part 8 planning procedure,
(b) sufficient documentation to demonstrate that the proposed designs can satisfy any
applicable planning constraints,
and, if so required subsequent to the submission of a tender, to provide such documentation
within a specified time.
Tenderers shall be deemed to have satisfied themselves, through consultation with the
Planning Authority or otherwise, that the proposed development will be such that the
Contracting Authority will decide to carry it out.” (ibid)
Pre-tender planning was particularly an issue for Group Water Schemes located in remote
areas often in designated special areas of conservation. Overly prescriptive planning
requirements could significantly increase project costs. Under the new arrangements, the
preferred bidders for a DBO contract engage with planners at an open day to discuss their
development proposals. This allows potential contractors to develop more innovative and cost
effective treatment plant designs to meet planning requirements rather than having their
design scope limited by planner imposed specifications. This Departmental initiative has
been deemed quite successful in improving value for money, while at the same time ensuring
that the protection of the natural environment is in no way compromised.
Criticism of DBO contracts
DBO projects have been regarded as being quite successful to date in terms of cost
effectiveness. One criticism that has been made though is that while DBOs are generally quite
cost effective at the Design Build phase, there is little incentive for the operator to innovate
with new technologies during the operational and maintenance phase to reduce costs. Even if
they do, the operator will pocket any savings as their existing revenue stream is guaranteed.
This assumes, however, that local authorities would innovate with new cost saving
approaches if they were running such plants, which might not necessarily be the case.
Provisions have been made in all DBO contracts for the dismissal of the DBO operator during
102
the 20 year O&M phase for non-performance. An independent arbitration process would
determine the buyout terms. The dismissal clause does provide a safeguard to ensure that
Group Schemes are not trapped in unsatisfactory DBO contracts.
Water Pricing Framework and the application of the Polluter Pays Principle
In March 2000, the Irish Government accepted the proposals of the Minister for the
Environment and Local Government for a water pricing framework (WPF) including the
following elements:
 collection of capital contributions by local authorities from non-domestic users in a
structured and uniform manner and in accordance with the polluter pays principle;
 operational costs in respect of the provision of water and waste water services to nondomestic users to be recovered in full based on usage, with an attendant adjustment to the
commercial rate;
The objective of the framework was to develop a more sustainable approach to water services
management by fully internalising the costs of water usage and waste water generation in
respect of the non-domestic sector, while making more explicit and transparent to domestic
users the costs of the services which they use. This was in keeping with the application of the
polluter pays principle which has been defined by the OECD as “the principle to be used for
allocating the costs of pollution prevention and control measures to encourage rational use of
scarce environmental resources...”. It was also in line with EU requirements (the Maastricht
Treaty states “that environmental damage should as a priority be rectified at source and that
the polluter should pay” (Article 130r)) [Departmental Circular L16 of 2002].
In practice, this meant that non-domestic water users would be charged the marginal capital
cost of building additional water treatment infrastructure capacity to meet non-domestic water
demand. They would also be charged for the operational and maintenance cost of being
supplied with treated water by Councils, when connected to the public mains. The
implementation of the WPF has been rolled out to local authorities since 2000 based on a
series of Departmental circulars consolidated into Circular L16/2002. As can be seen in
Appendix 6, there are also significant levels of non-domestic water demand in the Group
Schemes’ sector. Given the need for priority implementation of the Action Plan for Rural
Drinking Water Quality, a more streamlined approach has been adopted with the 15% Group
103
Water Scheme contribution being treated as the marginal capital contribution, for the purposes
of the Water Pricing Framework.
Effectiveness of DBO Solution
As these DBO plants were only coming into operation for the first time in 2006, there is
limited water quality test data available to assess the effectiveness of this water quality
upgrade solution. DBO Client Representatives have reported in most cases that the Group
Schemes are now fully compliant with the Drinking Water Directive based on the latest test
data. Cases where exceedances are still occurring are related to recontamination problems in
the pipe network rather than the treatment solution themselves. While DBO plants are fully
operated by trained professionals, the DBO operators’ responsibility ends once the treated
drinking water leaves the plant and enters the Group Schemes’ pipe network.
Effectiveness Risk Factors
DBO Client Representatives do recognise that there is a risk of recontamination of treated
water in the pipe network. The two risk factors are contaminants entering sub-standard pipes
and poor maintenance of pipe networks by Group Scheme members. These risk factors can be
reduced by replacing or repairing faulty pipe work and by periodically scouring/flushing out
pipes. In most cases, pipe network upgrades are being carried out in tandem with the
construction of the DBO treatment works so this will considerably reduce the re-infection
risk. This should ensure that water quality in the completed DBO Bundles is satisfactory.
The situation in relation to the maintenance of pipe networks is less clear. Some Group
Schemes have engaged caretakers on a professional basis to maintain their pipe networks.
This will considerably reduce re-infection risk. The Water Services National Training Group
and the National Federation of Group Water Schemes organise training for Group Scheme
members in pipe network maintenance. In some cases, Group Scheme volunteers have been
very diligent at maintaining their pipe networks so the risk of re-infection is low. However,
the standard of maintenance in other Group Schemes is less clear and the risk of re-infection
in the pipes is a potential problem. Given the millions of euros of taxpayers’ funds being
invested in building treatment plants and upgrading pipe networks, it is unacceptable that
104
water could become re-contaminated again before it reaches household taps due to poor pipe
network maintenance.
Possible future options for pipe network maintenance
It seems clear that in a scenario of decreasing volunteerism, it is not sustainable to continue to
expect pipe networks to be maintained on a non-professional basis. An alternative option
would have been to include pipe network maintenance as part of DBO operator duties.
Department of the Environment, Heritage and Local Government officials were asked why
this was not originally considered as an option. Two main reasons for this were outlined;
1. The consortia bidding for the DBO contracts were mainly involved in constructing and
operating water treatment plants and did not involve themselves in pipe network
maintenance. Pipe network upgrades were carried out separately under non-DBO
contracts.
2. The extension of DBO contracts to the operation and maintenance of the pipe
networks would essentially have completely contracted out their operation to
commercial concerns and this was a step that Group Water Schemes were reluctant to
accept as community organisations. This level of privatisation has not taken place in
the public schemes’ sector either although public DBO treatment plants are also in
operation.
An alternative option would be to have local authority staff carry out operation and
maintenance work on pipe networks. This would have the merit of having statutorily
accountable organisations responsible for a public health function, however it would also
involve an additional cost to the exchequer as current subsidy levels are based on Group
Scheme volunteerism. Whatever option is adopted, it is clear that additional investment will
have to be made in pipe network maintenance in the future and it is likely that some if not all
of this burden may fall on the exchequer because of the requirements of the Drinking Water
Directive.
105
DBO Solution - Existing Value for Money Conclusions
It is clear that value for money was a strong factor in developing DBO projects. Evidence of
this is shown by initiatives such as:

Bundling of DBO projects to attract innovative and competitive bids from the national
and international water infrastructure construction market

Merging/Sub-bundling of schemes to reduce the number of treatment plants required

Change from Pre-tender to post-tender planning to encourage more cost effective
designs

Transference of construction risk to DBO contractor by limiting capital cost increases

Economic plant design capacities with water conservation measures to reduce leakage
and over abstraction of water for treatment purposes
DBO Solution - Need for Value for Money Improvements
There are certain areas where value for money issues need to be addressed;
1. While the local authority questionnaire returns suggest that in most cases, the DBO
option was the most cost effective solution adopted, there is a need for greater
transparency in relation to this. It is recommended that for all future DBO project
proposals, a report should be prepared costing all alternative options to the DBO route
and comparing those costs to the DBO cost.
2. County Councils have stated that in most cases all alternative options to DBOs were
costed but verification of this was not provided, in most cases, within the time limits
of this Review. This verification should be included in the Final Accounts of all DBO
Bundles completed to date as well as confirmation of the final cost of the civil works
contract and the payment by each Group Scheme of their 15% capital contribution.
3. In cases where Group Schemes cannot be connected to existing public supplies due to
insufficient existing plant capacity, the cost of increasing existing water treatment
plant capacity must be included as an option.
106
4. The Department and local authorities should continue to assess opportunities for
achieving greater value for money by rationalising the number of water treatment
plants in DBO Bundles so that two or more Group Schemes can be served by the same
treatment plants.
107
Non-DBO Water Quality Upgrade Solution
Introduction
This is the water quality upgrade that has been identified for 21 of the 729 schemes (3%).
Non-DBO is a somewhat incongruous name but encompasses all water quality upgrade
solutions involving the installation of a stand alone treatment facility, not procured by way of
a DBO contract. In some cases, it simply involved upgrades to existing treatment
infrastructure. Responsibility for both the operation and maintenance of the treatment
infrastructure and the pipe network remains with Group Scheme volunteers. The Department
provides 85% grant aid up to a maximum of €6,476 per house with a 15% Group Scheme
contribution. Any necessary pipe network upgrades must also be funded from the same
€6,476 grant limit.
Solution Implementation and overall expenditure
As can be see from table 4.2.1 below, implementation under this treatment solution is
moderate at 24% as of June 2006. There is no overall expenditure figure available for this
treatment solution during the 2003-’06 period as works are funded out of the Upgrade
measure, which also includes pipe upgrade works and Disinfection/Sterilisation schemes.
From the data collected in the case studies below, it would appear, however, that capital
expenditure per house under this solution is minimal by comparison to the cost of the other
solution types
Table 4.2.1 – Implementation of the Non-DBO solution
Non-DBO Scheme
No. of Group
% implementation
Status
Schemes
In Planning
7
33%
Work in Progress
9
43%
Complete
5
24%
Total
21
Source: Report to the European Commission – June 2006 p.34.
108
Efficiency of non-DBO treatment solution
It was decided to examine the five schemes that were complete. These schemes were
identified from the list of completed schemes submitted by local authorities as part of the June
2006 Report to the European Commission. Monaghan County Council advised the
Department that the treatment infrastructure for one of these non-DBO schemes
(Magheracloone GWS) was installed long before the 2003-’06 period under review so there
was no capital expenditure to report. Financial data in relation to the other four completed
non-DBO scheme are listed in Table 4.2.2 below.
Table 4.2.2 - Financial Data re. Non-DBO Schemes
Pipe
Total
Capital
Scheme
No. of
Completion Capital DB Upgrade Capital
Cost per
County
Name
Houses P/E
Date
House (€)
Kerry
Cappanlea
7
120
Jul-01
€37,000
€30,500
€67,500
€9,643
Wexford
Adamstown
3
12
Jan-06
€5,303
€0.00
€5,303
€1,768
€1,886,519
€8,132
€399,231
€7,393
Claren/
Galway
Knocklehard
Cork South Kilcredan
Cost
Cost
€1,378,030
Not
232 720 operational
54 -
Cost
€508,489
Nov-04 €44,473.91 €354,757
Source: Local Authority data requests-January 2007
As can be seen from Table 4.2.2 above, the overall Scheme capital cost and cost per house
vary widely. Kerry and Cork South County Councils confirmed that the €6,476 per house
grant limits were not exceeded in the cases of Cappanlea and Kilcredan as the Group Schemes
paid the capital costs in excess of the grant limit. The Department is seeking certain
clarifications from Galway County Council in relation to the funding of Claren/Knocklehard.
It is noticeable in most cases that the cost of the pipe network upgrade was equivalent to or far
exceeded the cost of the water quality upgrade solution. The small number of houses explains
the high capital cost per house, in the case of Cappanlea. However, there is an adventure
109
centre attached to the Group Scheme. Therefore, even though the Group Scheme has less than
15 houses, it must comply with the Drinking Water Regulations, as there is a premises with a
commercial function attached to it. In 3 out of 4 cases the non-domestic water demand was
very low but it was 75% for Cappanlea. This is due to the water demand of the adventure
centre. In 2 out of 4 cases, the public mains were too distant for connection. In the case of
Cappanlea, Kerry County Council stated that there was insufficient capacity on the existing
public mains. In the case of Claren/Knocklehard, Galway County Council stated that
connection to the public main was initially proposed as a water quality solution in
correspondence with the Group Water Scheme. However, the Group Scheme rejected this
option and a standalone treatment facility was constructed instead. This is a matter for
concern as it appears that the Group Scheme exercised a veto in this case and a more
expensive solution was constructed instead. It is important that Group Schemes are consulted
in relation to water quality upgrade solutions, particularly as they have to contribute towards
the cost. However, a private Group Scheme cannot dictate that tax payers pay more than is
necessary to resolve their water quality problems.
Effectiveness of Non-DBO Treatment Solution
2005 EPA test data was checked to verify if the non-DBO Schemes were compliant with the
Drinking Water Directive after completion. Councils were also asked to confirm that the
Schemes were compliant based on 2006 water quality test results available to them. The
results are set out in Table 4.2.3 below and are extremely mixed. 4 out of 5 of the completed
non-DBO Schemes are still showing exceedances of Drinking Water Regulation parameters.
In the case of two of these upgraded Group Schemes - Cappanlea and Claren/Knocklehard,
there are exceedances of the E Coli microbiological parameters. Those two Group Scheme are
clearly not in compliance with the Drinking Water Regulations. This is, particularly, a cause
for concern with regard to Cappanlea in Kerry. This Group Scheme has a population
equivalent (p/e) of 120 due to the Adventure Centre attached to it. 2 of the remaining 3 Group
Schemes show exceedances of the less serious indicator parameters. Monaghan County
Council said that the coliform exceedance in Magheracloone was a one off incident
coinciding with maintenance works to part of the pipe network. Galway County Council
have explained that there have been delays in commissioning the Claren/Knocklehard
treatment plant so the treatment solution is not actually operational yet. This explains the
110
continuing exceedances of the E.Coli paramater even though the Group Scheme has officially
been upgraded.
Given the small number of schemes completed using this solution to date, it is difficult to
form a conclusive view in relation the effectiveness of the solution. It certainly needs to be
investigated further to clarify whether the solution is the problem or whether it is due to
inadequate maintenance by Group Scheme volunteers. If it is the latter, local authorities
should insist that members of the relevant Group Water Schemes participate in training
courses organised by the Water Services National Training Group (WSNTG).
Table 4.2.3 - 2005 and 2006 Exceedances of Drinking Water Quality Parameters
No. of
County
Kerry
Scheme Name
Cappanlea
Completion 2006
Houses P/E Date
7 120
2005 EPA
Exceedances Exceedances
E Coli ,
E coli, pH,
Coliforms,
manganese,
Jul-01 Iron, pH
Total
iron
Total
Coliforms and Coliforms and
Wexford
Adamstown
3
12
Jan-06 pH
pH
1 Coliform
exceedance &
Monaghan Magheracloone
Colour
E.coli,
Not
Galway
Claren/Knocklehard
Cork South Kilcredan
Coliform &
232 720 Operational E. coli
54
Nov-04 None
Manganese
None
Source: 2007 EPA Drinking Water Quality Report and Local Authority data
Conclusion
It is clear that the non-DBO solution is a residual treatment category for a small number of
Group Schemes, whose treatment solution is not DBO or Disinfection/Sterilisation based. It is
financially quite efficient but its effectiveness is questionable. Further analysis is necessary to
111
clarify whether the treatment solution itself or the operation and maintenance of the solution
is ineffective. If the latter is found to be the problem, local authorities should insist that
members of the relevant Group Water Schemes participate in training courses organised by
the Water Services National Training Group (WSNTG).
112
Public Water Supply Solutions
Introduction
As stated in this Review’s introductory chapter, water quality upgrade solutions fall into two
distinct categories. The first category involves the installation of water treatment
infrastructure to serve the Group schemes and comprises the DBO, Non-DBO and
Disinfection/Sterilisation solutions. The second category involves connecting Group Schemes
to the nearest public water supply, where this is possible, and discontinuing the use of their
sub-standard private water source. One of these solutions is called “Connection to the Public
Main” (CTPM), where the Group Scheme receives it water supply from the public mains but
remains responsible for the maintenance of its pipe network with a €50.89 annual operating
subsidy per domestic household. The CTPM solution has been identified for 118 schemes
(16%) of all schemes. The second solution is called “Takeover”, where a Group Scheme is
connected to the public mains and is completely taken over by the Council. In this case, the
Group Scheme effectively ceases to exist and its former members become public water
consumers. The local authority is responsible for both water treatment and maintenance of the
pipe network so no further operational subsidy payment is required. The Takeover solution
has been identified for 65 schemes (9%) of all schemes.
Implementation of Public Water Supply Solutions
The first striking characteristic of these public water supply solutions is the low level of
implementation of these solutions to date by comparison to the water treatment solutions.
According to the June 2006 Report to the European Commission, there were only 3 takeovers
and 6 CTPMs completed out of 65 schemes designated for takeover and 118 designed for
CTPM (see table 4.3.1 below). It will be shown later on in this chapter that there were
additional CTPM and Takeover works carried out but these were generally low priority works
unrelated to compliance with the Drinking Water Regulations. Overall expenditure for CTPM
and Takeover schemes, during the 2003-’06 period, were €16m and €46m respectively. It
should be noted that CTPM works were funded as part of the network upgrade measure up to
2003 so the €16m figure only covers the 2004-’06 period, when CTPM works had their own
separate capital measure.
113
Table 4.3.1 – Implementation of the CTPM and Takeover Solutions
Scheme Status
No. of CTPM
No. of Takeover
Schemes
Schemes
In Planning
85
35
Work in Progress
27
27
Complete
6
3
Total
118
65
Source: Report to the European Commission – June 2006 p.35-36.
Councils were asked to provide reasons why implementation to date was so low particularly
given the progress to date on the DBO treatment solutions. Councils offered a number of
reasons in their Questionnaire responses (Q.7.);

Delay in reaching agreement with Group Schemes on implementation of solution

Delays in getting 100% agreement by Group members

Lack of interest in some Schemes to takeover or CTPM

Concerns and suspicions re. chlorination of public water supplies

Unwillingness of non-domestic consumers on Group Schemes to pay commercial
water charges if connected to public mains

Problems with access to lands to allow connection to public mains

Lack of statutory powers to allow Council to impose solutions on non-co-operative
Group Schemes

Insufficient water capacity on public schemes

GWS don’t see benefit of paying 15% contribution towards civil works for CTPM,
when their O&M cost will increase and their subsidy payment will half, as subsidy
payment subsidises the non-domestic members of the GWS.
It would appear from the information supplied by Councils and anecdotal evidence that the
core reason why these projects are not progressing is that non-domestic users on Group
114
Schemes would be charged by the Council for water use, when they are connected to the
public mains. Most of these non-domestic users would be relatively heavy water users, and
regard it in their commercial interest to remain on private water supplies, even if those water
supplies are seriously deficient. As most Group Schemes currently require 100% agreement of
their membership to be taken over or to be connected to the public main, a minority of
members can hold up progress.
While this is a logical position to hold from a purely commercial perspective, it is simply not
acceptable or sustainable from a public health perspective. Quite apart from that, the Irish
taxpayer will be required to pay significant fines to the European Commission if sub-standard
private water supplies like these are not upgraded to comply with the Drinking Water
Directive. As already stated, at the start of this chapter, Councils were empowered to take
prosecutions against non-compliant Group Schemes under the Drinking Water Regulations
2000. The Minister for the Environment, Heritage and Local Government gave local
authorities additional powers to carry out remedial works, without Group Schemes’ consent
where necessary, and charge the cost to Group Schemes under the 2007 Drinking Water
Regulations (S.I. No. 106 of 2007). The Department believes that with the new Regulations,
Councils will have the necessary powers to proceed with the implementation of these two
water quality upgrade solutions. Of course, having legal powers and enforcing them are two
different things so it waits to be seen whether local authorities will exercise these powers, the
reaction of volunteer Group Scheme trustees and the outcome. The National Rural Water
Monitoring Committee (NRWMC) previously appointed a national co-ordinator to oversee
DBO project implementation. In light of the successful ongoing implementation of that
solution, the NRWMC has decided to extend the remit of a newly appointed national coordinator to also oversee the implementation of the CTPM and Takeover solutions by
Councils.
Efficiency and Effectiveness of Public Water Supply Solutions
Given the limited implementation to date of these two upgrade solutions, it was only possible
to examine a relatively small number of schemes to assess effectiveness and efficiency.
115
Connection to the Public Mains (CTPM) Upgrade solution
As has already been stated above, this solution has been identified for 118 schemes (16% of
overall schemes) previously being served by sub-standard private water sources. The Group
Scheme is connected to the nearest available public water supply so no longer has any
responsibility for treating the water. The Group Scheme does remain responsible for the
maintenance of its pipe network with a €50.89 subsidy per house. The capital cost of
connecting to the public mains is 85% funded by the State with a 15% Group Scheme
contribution. Councils have reported that some Group Schemes object to paying this 15%
contribution on the basis that they are being connected to the public mains, while other public
water users do not have to pay such a contribution. Also, Group Schemes that are completely
taken over by Councils do not have to pay any capital contribution. The overall Departmental
grant for connecting a Scheme to the public mains cannot exceed €6,476 per house. This grant
limit also includes any necessary pipe network upgrades. Five completed CTPM schemes
were selected to assess their efficiency and effectiveness and the results of these case studies
are outlined below.
Efficiency of CTPM solution
The first point to note is that additional pipe network upgrades were carried out in all cases
below. Also, the cost of the pipe network upgrade exceeded the cost of connecting the Group
Scheme to the public mains in all five cases. It should be noted that there was a complete
network replacement in the case of Carrowmeena. These pipe network upgrades were
necessary to address UFW and to reduce the risk of re-infection in the pipes. County Councils
have confirmed that competitive procurement was used for works on all 5 Group Schemes. As
can be seen below, the total cost per house of this solution varies widely from scheme
depending on their unique situation and in two cases the capital cost exceeded the €6,476 per
house. However, Leitrim County Council confirmed that the €6,476 grant limit was not
exceeded for Corraleehan due to the Group Scheme contribution. Clare County Council
explained that it is intended that Ballagh/Cahersherkin will be completely taken over by the
Council so the €6,476 per house grant limit doesn’t apply in this case.
116
Table 4.3.2 – Financial data on CTPM Schemes
County
Completion No. of
Council Scheme Name Date
Pipeline
Network Total
Distance Connection Cost
Upgrade Upgrade Cost per
Cost (€)
Cost (€)
Houses (km)
per Km Cost
Total
House(€)
Ballagh/
Clare
Cahersherkin
Mar-07
170
4.495
Donegal Carrowmeena
Aug-03
47
1.3
411,214 91,483
0
985,850 1,397,064
8,218
0
215,975
215,975
4,595
Cloonmore
Galway
No. 1/Killilane
Apr-05
73
0.63
25,200 40,000
59,850
85,050
1,165
Mayo
Bekan
May-05
146
2
100,000 50,000
548,653
648,653
4,443
Leitrim
Corraleehan
Jun-02
268
0 1,234,405 1,888,164
7,045
-
653,759
Source: Data requested from Local Authorities – January 2007
Effectiveness of CTPM Solution
The latest available 2005 EPA test results and data from local authorities was examined to test
the compliance of these Group Schemes with the Drinking Water Regulations after
connection to the public water supply. There were no exceedances reported by Clare County
Council for Ballagh/Cahersherkin after connection to the public main. Cloonmore No.1
/Killilane exceeded the manganese parameter but this is only an indicator parameter. On the
other hand, Corraleehan had exceedances of the microbiological E. coli parameter in 2005,
even though it was connected to the public mains in 2002. Leitrim County Council reported
that they followed up this incident and the problem was resolved with all tests subsequently
being passed. No assessment can be made of the effectiveness of the CTPM solution for
Bekan or Carrowmeena Group Schemes as they do not appear to have been tested at all since
they were connected to the public main. Donegal and Mayo County Councils are legally
required under the Drinking Water Regulations to test all private water supplies serving >15
houses and/or with a commercial/public use connection but this does not appear to have
occurred in 2005.
117
Table 4.3.3 – 2005 and 2006 Exceedances of Drinking Water Quality
County
Council
Completion
Scheme Name
Date
2005 EPA Exceedances 2006 Exceedances
Ballagh/
Clare
Cahersherkin
Mar-07 Colour and Odour only
Donegal
Carrowmeena
Aug-03 No testing done
No
Cloonmore No.
Galway
1/Killilane
Apr-05 No exceedances
Manganese only
Mayo
Bekan
May-05 No testing done
No
Bacterial contamination
E.Coli and coliform
Leitrim
Corraleehan
Jun-02 bacteria
incidents followed up and
resolved
Source: 2007 EPA Drinking Water Quality Report and Local Authority data
It would appear from this relatively small sample and the latest 2006 exceedances data that
the connection to the public mains is a relatively effective water quality upgrade solution. A
larger sample is needed to definitely confirm this but successive EPA drinking water quality
reports have categorised public source water quality as satisfactory. The main risk factor is
re-infection in the pipe network due to poor network maintenance by the Group Schemes
although the above five Councils have not cited this as a risk factor for the above schemes.
118
Takeover Upgrade Solution
As already stated, this water quality upgrade solution involves the complete takeover of
Group Schemes by their local authority. The Group Schemes are connected into the public
mains and the Council becomes totally responsible for the maintenance of the pipe network,
which transfers to Council ownership. This solution receives 100% capital funding with no
Group contribution and no grant ceiling. The Department has made a conscious decision not
to require a Group Scheme contribution for complete takeover of schemes by local
authorities. Takeover is regarded as the best guarantee of addressing water quality issues as
the former Group Scheme members will receive their water from the public supply and will
have their pipe networks professionally maintained by local authority staff.
Efficiency of Takeover Solution
Table 4.3.4 – Financial data on Takeover Schemes
Pipeline
No. of
Scheme Name
Cost
Network Total
Total
Distance Connection per Km Upgrade Upgrade
Cost (€)
Complete Houses (km)
(€)
Cost (€)
Cost (€)
Cost per
House (€)
Craans/Newstown
Nov-06
56
5.3
455,000 85,849
0
455,000
8,125
Cloonminda
Apr-04
54
0.246
10,000 40,650
227,032
237,032
4,389
Kilkerly
Mar-04
46
0.71
67,166 94,600
0
67,166
1,460
Source: Data requested from Local Authorities – January 2007
Councils provided financial data for the above three schemes. Data was also requested from
Roscommon County Council for Carane Whitehall and from Mayo County Council for the
Clare Island takeover. Mayo County Council explained that there was no expenditure
involved in taking over the Clare Island scheme and Roscommon did not provide the
requested data. As can be seen, the takeover costs vary widely and in the case of Cloonminda
the pipe network upgrade cost far exceeded the connection to the public mains cost. The
Craans/Newstown takeover in Co. Carlow was particularly expensive at €8,125 per house. It
should be noted though that there is no grant ceiling for takeovers and they are 100% grant
aided by the Department. Generally, connections to the public main (CTPM) and takeover are
119
cheaper than standalone DBO treatment plants. But there are situations where there is no
adequate water source for a standalone plant so connection to a distant public mains may be
the only technical but expensive option.
Effectiveness of Takeover Solution
The effectiveness of the takeover solution was assessed based on the latest available EPA data
for 2005 and test result data provided by Councils for 2006. No tests were carried out on
some of these schemes post take over as they no longer exist as Group Schemes and are now
part of the public mains. This is legally in order as only certain sections of the public mains
supply are sample tested, whereas all Drinking Water Regulated Group Schemes must be
tested.
Table 4.3.5 – 2005 and 2006 Exceedances of Drinking Water Quality
County
2006
2005
Council
Scheme Name
Carlow
Craans/Newstown
Nov-06 None
Nitrate
Galway
Cloonminda
Apr-04 None
None
Mayo
Clare Island
Roscommon Carane Whitehall
Louth
Kilkerly
Complete Exceedances
Exceedances
No data
None
None
No data
No Data
No Tests
Mar-04 None
No Tests
Source: 2007 EPA Drinking Water Quality Report and Local Authority data
As the above 5 Group Schemes are now fully connected into the public mains and their pipe
networks are being maintained by local authority technical staff, it is safe to conclude that this
water quality upgrade solution is effective, in spite of the lack of test result data, based on
EPA reports in relation to the satisfactory standard of public drinking water quality.
120
Takeover and CTPM works unrelated to the European Court of Justice (ECJ) case
In view of the apparent lack of implementation of the CTPM and Takeover water quality
upgrade solutions in the June 2006 report to the European Commission, Councils were asked
in the November 2006 Questionnaire (Q8) to list all the Group Water Schemes taken over and
CTPM during the 2003-'06 period. The response received was that 142 Schemes were taken
over and 94 schemes were CTPMs. These figures differ considerably with the June 2006
Report to the European Commission of 3 Takeovers and 6 CTPMs. In both cases, the number
of completed CTPMs and Takeovers exceeded the total schemes designated for these
solutions in the June 2006 Report (see Table 4.3.6 below). Needless to say, this difference
cannot be merely explained away by speculating that there was a substantial increase in
solution implementation in the second half of 2006.
Table 4.3.6 – Comparison of June 2006 and Jan 2007 CTPM/Takeover completions
Solution Category
Total Schemes
June 2006
Jan 2007
Designated per
Report
Questionnaire
Solution
Completions Completions
Takeovers
65
3
142
CTPM
118
6
94
Scheme Totals
183
9
236
Source: Q8 Local Authority Questionnaire Returns (Jan 2007) & June 2006 Report to the European
Commission p.35-36.
In trying to reconcile this considerable difference, a number of explanations were found;
1. Public Source – A number of schemes were misclassified under this heading in the June
2006 Report to the European Commission when in fact they were completed CTPM schemes
now connected to the public mains. In other words, the number of private source schemes
connected to the public mains during the 2003-’06 period was undercounted in the June 2006
Report to the European Commission.
121
2. Takeovers - Of the 142 schemes taken over by Councils, 92 were already on the public
mains and 50 were on a private source. The Department’s current policy is that sub-standard
private source schemes should be taken over as a matter of priority. Group Schemes, already
connected to the public mains, should not be taken over unless strictly necessary.
Table 4.3.7 - Breakdown of Completed Takeovers into Public/Private Source Schemes
Completed Takeovers
Public Source
Private Source
Total
Total
92
50
%
65%
35%
142
100%
Source: Q8 Local Authority Questionnaire Returns (Jan 2007)
The data supplied in local authorities returns in Table 4.3.7 above would suggest that 65% of
all Group Schemes taken over by local authorities during the 2003-’06 period were already on
the public mains and only 35% were on a private source, when taken over.
3. Schemes not on June 2006 list of Schemes to European Commission - There are more
schemes in total taken over and CTPM during 2003-06 period than are actually designated for
these treatment solutions in the overall lists sent to the European Commission in June 2006
(see Table 4.3.6 above). This is explained by the fact that quite a number of Schemes CTPM
and taken over during 2003-06 do not appear on the list of schemes sent to the European
Commission. In other words, quite a large number of the schemes taken over or CTPM during
2003-’06 were not required to comply with the Drinking Water Directive at all due to their
small size and were not relevant to the European Court of Justice (ECJ) case against Ireland.
So while implementation under the priority Schemes has been very slow, capital funds appear
to have been drawn down by some Councils to takeover or connect non-priority Group
Schemes to the public mains.
122
Council Explanations
Several Councils were contacted and asked to explain why there was so much CTPM and
Takeover activity underway on small non-priority Group Scheme, particularly given the low
level of implementation on priority schemes. Councils offered several explanations

In some cases, there were serious quality problems with smaller Group Schemes.
These Schemes were connected to the public mains or take over on public health
grounds, even though they were too small to require compliance under the Drinking
Water Regulations.

Some smaller Group Schemes requested to be connected to the public mains or be
taken over as they did not have the resources to maintain the Scheme themselves.
Departmental view
Departmental officials point out that they have always emphasised to Councils the need to
advance priority CTPM and Takeover projects over the 2003-’06 period. They do concede
that it is possible that some Councils were committed to carrying out lower priority projects at
the start of the 2003-’06 period. Councils were invited by the Department to submit bids for
their 2007 block grants on 7th December 2006. They were specifically instructed to prioritise
projects, which needed upgrading to comply with the Drinking Water Directive, ahead of any
other projects because of the implications of the ECJ ruling. The Department still received
‘elaborate proposals’ for takeovers of low priority Group Schemes in the 2007 local authority
bids. These proposals were rejected by the Department and did not receive funding under the
2007 block grant allocations. It is clear that that the Department has given unambiguous
instructions to local authorities to only advance CTPMs and Takeovers for priority Group
Schemes. Expenditure on water quality upgrades, unrelated to the ECJ case, was necessary so
it should not, in any way, be regarded as wasted. However, it is important that funding
targeted at high priority schemes should be spent on those high priority schemes. New
performance indicators will be recommended in Chapter 6 to try and ensure this.
Comparison of Local Authority water charges to DBO O&M costs
It is clear from the Questionnaire returns from local authorities and anecdotal evidence that
the key issue holding up the implementation of the CTPM and the Takeover solutions is the
reluctance of some non-domestic water consumers on Group Schemes to be connected to the
123
public water supply due to local authority water charges. There is also a clear preference on
the part of such consumers for the DBO treatment plant option, as they perceive this to be the
cheaper option in terms of ongoing operation and maintenance (O&M) costs for them. The
ongoing O&M costs for Group Schemes of the respective water upgrade solutions is not
directly an issue for the Department beyond the payment of the annual domestic household
subsidy. It is, however, impacting on the implementation of the Rural Water Programme and
increasing the risk of European Court of Justice (ECJ) fines for non-compliance with the
Drinking Water Regulations. Therefore, it is important that this Review briefly examines the
issue of comparative O&M costs for DBO and Public Source Group Schemes.
Local Authority Water Charging System
Local authorities are required to charge all non-domestic consumers for their water usage,
under the terms of the Government’s Water Pricing Framework (Circular L16/2002). This
also applies to any non-domestic consumers on Group Water Schemes connected into the
public water supply. In addition, non-domestic water consumers on any private source Group
Water Schemes, which are subsequently taken over by their local authority and absorbed into
the public water supply system, are also required to pay water charges to the local authority.
As domestic water consumers on the public mains are not directly required to pay water
charges (the costs of which are funded through central taxation), the Department recommends
that domestic water consumers on publicly sourced Group Schemes should be given a free
water allowance of 50,000 gallons per house per year (227 cubic meters) by their local
authority. Connections, with both domestic and non-domestic water needs e.g. farms, should
also be given an annual 50,000 gallons allowance for domestic purposes (Subsidy
Memorandum 2002, p.6.). Councils should charge for any water usage above and beyond the
permitted allowance. Water charging levels differ from Council to Council both in terms of
fixed connection charges and volumetric water usage charges. Councils also apply different
domestic water allowances to Group Scheme consumers. All Councils providing water to
Group Schemes, with the exception of Kilkenny and Kerry County Councils, use exactly the
same charging rates for Group Scheme non-domestic consumers as for non-domestic water
consumers, who are fully on the public mains. These charges are set out in Table 4.3.8 below.
Some Councils reported that they do not currently have any active Group Schemes connected
to the public mains so they are marked non-applicable (N/A).
124
Table 4.3.8 – Table of annual local authority water charges for public Group Schemes (2006)
Annual
Same as Vol. charge Fixed
Initial
Free Dom.
Urban per M3 of Charge per Connection Water m3
charges water (€) connection Fee per hse Allowance
Yes
€0.86
€290 €750 - €2500
€190
Carlow
N/A
N/A
N/A
N/A
N/A
Cavan
Yes
€0.76
€211
€1,050
227
Clare
€0.84
€220
€670
155
Cork North Yes
€0.84
- No Limit
Cork South Yes
€0.84
€230
€650
155
Cork West Yes
Yes
€1.40 €236- €436
Varies
228
Donegal
Yes
€0.73
€0
Varies
227
Galway
No
€0.52
€50
228
Kerry
Yes
€1.28
€578
€431
€242
Kildare
No
€0.69
€38
€1,000
182
Kilkenny
Yes
€1.09
€50
€0
227
Laois
Yes
€0.74
€60
€650
227
Leitrim
Yes
€0.86
€0
€600
227
Limerick
Yes
€1.09
€100
€600 No Limit
Longford
N/A
N/A
N/A
N/A
N/A
Louth
Yes
€0.00
€0
€1,500
227
Mayo
N/A
€0.00
€0.00
€0.00
N/A
Meath
€0.80
€0
€0
None
Monaghan Yes
Yes
N/A
N/A
N/A
N/A
Nth Tipp
Yes
€1.01
€0
€500
227
Offaly
€0.92
€0
€880
227
Roscommon Yes
Yes
€1.25
Varies
€0
227
Sligo
€0.83
€0
€0 No Limit
South Tipp Yes
N/A
N/A
N/A
N/A
Waterford Yes
€0.95
€0
€0
227
Westmeath Yes
N/A
N/A
N/A
N/A
N/A
Wexford
Yes
€1.13
€40
€0
170
Wicklow
Source: Q20-21. Local Authority Questionnaire Returns – January 2007
County
Council
DBO Operation & Maintenance (O&M) Costs
Several DBO treatment plant bundles are now starting to come into operation. Early, and it
must be stressed provisional, O&M charging data has been supplied by DBO client
representatives for the purposes of this Review. The DBO operators’ estimated fixed cost per
house and volumetric cost per cubic meter of water charges for the Galway No. 1, Clare and
East Sligo DBO Bundles are set out in the Tables 4.3.9 below. The local authorities’
corresponding fixed and volumetric water charges for non-domestic consumers on publicly
sourced Group Schemes in the same counties are summarised in Table 4.3.10 below.
125
Tables 4.3.9 – Provisional DBO operator annual water charging rates
Fixed
Variable
Galway DBO 1 Scheme Costs per cost per
Names
House
m3
Ardrahan
€112
€0.15
Ballyglass/Fiddane
€113
€0.20
Brierfield
€115
€0.20
Caherlistrane
€107
€0.10
Cleggan/Claddaghduff
€107
€0.30
Cloonatleva
€113
€0.18
Cloonluane
€109
€0.20
Inis Meain
€109
€0.33
Kiltevna
€107
€0.19
Toberowen Lissybroder
€107
€0.19
Lettergesh
€108
€0.28
Lowville
€120
€0.29
Milltown
€108
€0.25
New Inn
€110
€0.12
Rinn Killeeneen
€113
€0.55
Fixed O&M Volumetric
Clare DBO Group Costs per hse Cost per
Scheme Names
per year
M3
Lissycasey
€92
€0.13
Killone
€92
€0.18
Toonagh/Dysart
€92
€0.18
Kilmaley/Inagh
€92
€0.10
Fixed
O&M
East Sligo DBO
Costs per Volumetric
Scheme Names
house
Cost per M3
Geevagh/Highwood
€215
€0.33
Keash
€215
€0.22
Culfadda
€215
€0.17
Corrick
€215
€0.33
Castlebaldwin
€215
€0.23
Source: DBO Client Representatives – January 2007
126
Table 4.3.10 – County Council Water Charging Rates 2006
County Council
Annual Fixed
Cost per m3 of
Cost
water
Galway
Nil
€0.73
Clare
€211
€0.76
Sligo
Varies
€1.25
Source: Q20-21. Local Authority Questionnaire Returns – January 2007
It would appear from this rough comparison that the DBO Bundles provisional O&M cost
volumetric rates are significantly lower than those charged by the three corresponding local
authorities. It would appear from the perspective of a non-domestic water consumer that they
receive better value for money in terms of operating costs by being connected to a DBO
treatment plant than being connected to the public mains or taken over. It must be stressed
again that the DBO O&M costs figures are provisional and may turn out to be significantly
understated but it is clear that anecdotal knowledge of this apparent cost differential is
encouraging non-domestic consumers on Group Schemes to delay or obstruct connection to
the public mains.
It should be borne in mind that local authority charges also include network maintenance
charges, which are not part of the DBO operators’ responsibility. It should be noted though
that local authorities only maintain the public part of the pipe networks and not the privately
owned Group Scheme portion. The Department’s domestic subsidy partially contributes
towards the network maintenance costs for domestic Group Scheme householders, while nondomestic Group Scheme consumers must directly contribute towards their network
maintenance as well as pay local authority water charges. It is not clear, however, whether
network maintenance costs fully explain the difference in charges. The apparently significant
operational cost differential between Group Scheme DBO and local authority run water
treatment plants lies outside the terms of reference of this particular Review but it is a matter
that should be examined more closely by the Department and local authorities on value for
money grounds.
127
Conclusions
It would appear based on the case studies examined that both the CTPM and Takeover public
source upgrade solutions are effective and relatively cost efficient. As with other water quality
upgrade solutions, there are significant costs involved in upgrading the pipe networks in
addition to the water quality upgrade costs. There is an effectiveness risk factor for CTPM
Schemes as the Group Schemes remain responsible for the maintenance of the pipe networks.
This is not an issue for takeover schemes as they are fully absorbed into the public water
system and are maintained by local authority technical personnel. Implementation is the real
problem for public source solutions due to local authority water charges for non-domestic
Group Scheme consumers. However, the Department has taken steps to ensure that Councils
must only advance high priority projects, requiring compliance with the Drinking Water
Regulations first. County Councils have now also been given greater legal enforcement
powers to deal with non-co-operative Group Schemes.
128
Disinfection/Sterilisation Water Quality Upgrade Solution
Introduction
This is the water quality upgrade that has been identified for 122 of the 729 schemes (17%).
Although, there are a large number of schemes using this solution, it is mainly clustered into a
small number of counties, which receive their water from mainly groundwater sources. The
natural chemistry of this raw water is generally quite good so basic chlorination is availed of.
The National Rural Water Monitoring Committee (NRWMC) expressed reservations in
relation to this minimal treatment solution in their 2005 Review of their Action Plan. In this
review, “the NRWMC questions the sustainability of this approach and recommends that each
Council review the quality of the raw water (based on source monitoring) and look again at
the appropriateness of this solution” (2005, p.8.). There were also concerns in relation to the
possible creation of potentially carcinogenic Trihalomethanes (THMs) if untrained Group
Scheme volunteers mixed incorrect amounts of chlorine into water generating THMs.
Solution Implementation and overall expenditure
As can be see from Table 4.4.1 below, implementation under this treatment solution is very
high at 75% as of June 2006. However, much of this work was carried out prior to the 2003’06 period under review so this level of output is not really comparable to implementation
under the other upgrade solutions. There is no overall expenditure figure available for this
treatment solution during the 2003-’06 as works are funded out of the Upgrade measure,
which also includes pipe upgrade works and non-DBO schemes. From the data collected in
the case studies below, it would appear, however, that capital expenditure per house under this
solution is minimal by comparison to the cost of the other solution types. It is grant aided up
to a maximum of €6,476 per house with a 15 % Group Scheme contribution. Any necessary
pipe network upgrades must also be funded out of the grant maximum.
Table 4.4.1 – Implementation of Disinfection/Sterilisation Solution – June 2006 Report, p.39.
Scheme Status
No. of Group Schemes
% implementation
In Planning
19
16%
Work in Progress
11
9%
Complete
92
75%
Total
122
129
Case Studies
As already stated, the Disinfection/ Sterilisation solution is mainly clustered into a relatively
small number of local authority areas. Four County Councils were contacted by phone and email in relation to this treatment solution. Each Council was questioned as to the effectiveness
and efficiency of this treatment solution. North Tipperary County Council and Offaly County
Council installed their disinfection/sterilisation equipment prior to the 2003-’06 period under
review so they were not asked to provide historical cost data as it would not be comparable to
more recently upgraded schemes. The Councils did say that capital expenditure on these
schemes were minimal with the installation of chlorinators costing less than €10,000 each.
Louth and Kilkenny County Councils did have schemes completed more recently so were
asked to provide cost data to assess the efficiency of this treatment solution.
North Tipperary County Council
North Tipperary County Council has the greatest number of such schemes but all of these
schemes were upgraded prior to the 2003-’06 period under review. The Council believe that
this is a sustainable treatment solution and monitor such Schemes closely to ensure that they
are properly maintained. They have not encountered any problems with THMs but concede
that monitoring of Group Schemes is vital.
Effectiveness
The 2005 EPA results for North Tipperary County Council were checked to verify if there
were any exceedances of the Drinking Water Regulations water quality parameters. All of the
39 Group Schemes already upgraded using Disinfection/Sterilisation were tested and 7
exceedances were identified. 5 of these are indicator parameters but 1 exceedance related to
the presence of the E.coli microbiological parameter in Fantane Group Scheme. The Council
explained that there were specific problems in relation to that Scheme, which they are
currently seeking to resolve and that that Group Scheme would not be representative of
schemes in North Tipperary. There was also a nitrates exceedance in Ballycasey. The EPA
Report for 2005 stated that the overall rate of compliance with the Drinking Water Directive
in North Tipperary for both public and private group schemes was good and well above the
national average (EPA 2007,p.87.). The EPA commented that North Tipperary County
Council carried out no monitoring of private water supplies that supply water as part of a
130
public or commercial activity. Two Schemes were tested for THMs but there were no THM
parameter exceedances. Given that only two schemes in thirty nine in North Tipperary are not
compliant with the microbiological and chemical parameters of the Drinking Water
Regulations, there is no evidence that the Disinfection/Sterilisation water quality treatment
solution is not effective.
Table 4.4.2 – North Tipperary Disinfection/Sterilisation Schemes Exceedances 2005
Water Supply Zone
Date
Parameter
Result
Units
Ballycasey
1-Mar-05 Nitrate
69.3
mg/l
Barnane
22-Mar-05 Colour
58
Hazen
Barnane
22-Mar-05 Turbidity (at tap)
17.2
NTUs
Cullenagh
28-Nov-05 Coliform Bacteria
7
No/100ml
Fantane
16-Aug-05 Coliform Bacteria
19
No/100ml
Fantane
16-Aug-05 E. coli
3
No/100ml
Graigue Pouldine
23-Mar-05 Colour
25
Hazen
Luska
22-Nov-05 Ammonium
0.43
mg/l
Plunkett St,Tullaheady
28-Sep-05 Coliform Bacteria
2
No/100ml
Source: 2005 EPA Drinking Water Report CD (2007)
Offaly County Council
Fifteen out of nineteen Group Schemes in Offaly were originally due to be upgraded with the
construction of DBO treatment plants. However, this proposal did not proceed on grounds of
economic viability. Therefore, it was decided to maintain the Groups’ existing
disinfection/sterilisation equipment as the main water treatment system for these fifteen
schemes.
Effectiveness
All of the 15 Group Schemes upgraded using Disinfection/Sterilisation were tested and
exceedances were identified in 8 schemes, in the 2005 EPA results. 7 of these exceedances
were of indicator parameters but 1 exceedance related to the presence of the E.coli
microbiological parameter in Killeigh/Cloneygowan Group Scheme
131
Table 4.4.3 – Offaly Disinfection/Sterilisation Schemes Exceedances 2005
Water Supply Zone
Date
Parameter
Result
Units
Aghancon G.W.S.
17-Jan-05 Coliform Bacteria
53
No/100ml
Bloomhill G.W.S.
18-Oct-05 Coliform Bacteria
200
No/100ml
Boher G.W.S.
19-Sep-05 Coliform Bacteria
16
No/100ml
Clareen G.W.S.
22-Mar-05 Colony County at 22C
119
No/ml
Clondelara G.W.S.
21-Feb-05 Iron
262
ug/l
Durrow G.W.S.
3-Oct-05
Coliform Bacteria
89
No/100ml
Durrow G.W.S.
22-Aug-05 Coliform Bacteria
70
No/100ml
Killeigh/Cloneygowan G.W.S.
10-Jan-05 Coliform Bacteria
25
No/100ml
Killeigh/Cloneygowan G.W.S.
5-Sep-05
53
No/100ml
Killeigh/Cloneygowan G.W.S.
13-Jun-05 Colour
29.3
Hazen
Killeigh/Cloneygowan G.W.S.
10-Jan-05 E. coli
2
No/100ml
Mountlucas G.W.S.
13-Jun-05 Coliform Bacteria
16
No/100ml
Mountlucas G.W.S.
5-Sep-05
16
No/100ml
Coliform Bacteria
Coliform Bacteria
Source: 2005 EPA Drinking Water Report CD (2007)
Offaly County Council explained that this E.coli exceedance was an isolated incident and was
not representative of Group Schemes in Offaly. The EPA Report agreed with this stating that
“the microbiological quality of the private group schemes was also good”. The EPA
commented that Offaly County Council carried out no monitoring of private water supplies
that supply water as part of a public or commercial activity. The EPA also commented that
“compliance with the indicator parametric values in private Group Schemes was higher than
that in the public water supplies through compliance with the coliform bacteria parametric
value was less than satisfactory (88%) and in need of improvement (EPA 2007, p.88.) Nine
Schemes in Offaly were tested for THMs are there were no exceedances of that parameter. In
general though, the Disinfection/Sterilisation water quality treatment solution appears to be
relatively effective in Offaly.
132
Kilkenny County Council
Fifteen of the twenty five Group Schemes in Kilkenny requiring a water quality upgrade were
treated using the disinfection/sterilisation solution. Only eight of these fifteen schemes were
upgraded during the 2003-’06 period under review. The efficiency and effectiveness of these
eight schemes are considered below.
Efficiency
As can be seen from the table below, the disinfection/sterilisation water treatment solution is
very cheap with the treatment cost per house ranging from €40 to €595 per house. Additional
network upgrade works were carried out, however, for 4 of the 8 schemes. This increased the
overall cost of compliance per house to between €1,333 and €4,147 for these four schemes. It
should be noted, however, that some of this network upgrade work included extensions of the
network, which would not have been strictly necessary to upgrade the water quality of
existing houses. The Council said that they have no ongoing current cost commitments in
relation to these Group Scheme apart from the normal subsidy payment.
Table 4.4.4 – Kilkenny Disinfection/Sterilisation costs
Network
Treatment
Treatment Upgrade/ Total
No. of Completion Solution
Scheme Name
Ballymack
Cost (€)
Houses Date
Solution
Total Cost
Extension Upgrade
Cost per
per house
Cost (€)
House (€) (€)
Cost (€)
68
2005
15,000
165,000
180,000
221
2,647
123
Dec-03
12,000
498,000
510,000
98
4,146
Dunmore
30
Dec-05
5,561
0
5,561
185
185
Kilree Stoneyford
32
Apr-05
16,100
0
16,100
503
503
Maddoxtown
30
Jun-05
1,200
0
1,200
40
40
Newtown Kells
42
Dec-04
25,000
125,000
150,000
595
3,571
Seskin
90
Dec-05
30,000
90,000
120,000
333
1,333
Windgap
55
Sep-04
9,160
0
9,160
167
167
Caherlesk/Coolaghmore
Source: Kilkenny County Council 2007
133
Effectiveness
As can be seen in Table 4.4.5 below, exceedances of the Drinking Water Regulations were
recorded in 7 of the 8 Group Schemes upgraded during the 2003-’06 period. However, 3 of
these schemes only exceeded the less serious indicator parameters. Of the remaining 4, Kilree
Stoneyford GWS had e.coli contamination and Dunmore, Maddoxtown and Windgap all had
nitrate exceedances. Kilkenny County Council have advised the Department that there were
further exceedances of the nitrates parameter for Maddoxown and Dunmore in 2006 and that
investment in a further nitrates treatment solution will be required in both cases. Kilree
Stoneyford GWS also subsequently had both an e coli and nitrate exceedance in 2006 and
Kilkenny County Council have noted that this scheme is vulnerable to pollution if chlorine
dosing is not implemented properly.
Table 4.4.5 – Kilkenny Disinfection/Sterilisation Schemes Exceedances 2005
Water Supply Zone
Date
Parameter
Result
Units
Ballymack GWS
20-Dec-05
Coliform Bacteria
4.1
No/100ml
Caherlesk-Coolaghmore GWS
14-Apr-05
Manganese
225
ug/l
Dunmore GWS
21-Dec-05
Nitrate
52.36
mg/l
Kilree Stoneyford GWS
12-Apr-05
Clostridium perfringens
10
No/100ml
Kilree Stoneyford GWS
12-Apr-05
Coliform Bacteria
60.1
No/100ml
Kilree Stoneyford GWS
12-Apr-05
E. coli
2
No/100ml
Maddoxtown GWS
23-Sep-05
Clostridium perfringens
31
No/100ml
Maddoxtown GWS
12-Apr-05
Coliform Bacteria
3.1
No/100ml
Maddoxtown GWS
12-Apr-05
Nitrate
52.09
mg/l
Maddoxtown GWS
20-Dec-05
Nitrate
56.17
mg/l
Newtown Ovenstown GWS
27-Jun-05
Coliform Bacteria
27.5
No/100ml
Newtown Ovenstown GWS
27-Jun-05
Coliform Bacteria
27.5
No/100ml
Newtown Thomastown GWS
3-Feb-05
Coliform Bacteria
6
No/100ml
Newtown Thomastown GWS
5-Apr-05
Coliform Bacteria
1
No/100ml
Windgap GWS
14-Apr-05
Coliform Bacteria
8.6
No/100ml
Windgap GWS
4-Apr-05
Nitrate
55.5
mg/l
Windgap GWS
14-Apr-05
pH
6.29
Source: 2005 EPA Drinking Water Report CD (2007)
134
Given that four of the eight schemes (50%) upgraded using the Disinfection Sterilisation
treatment solution during the 2003-’06 period are still quite clearly non-compliant with the
Drinking Water Regulation’s microbiological and chemical parameters, one has to question
the effectiveness of this treatment solution in Kilkenny. The Council did, however, also
provide water quality test data in relation to the 7 disinfection/sterilisation schemes upgraded
prior to 2003 and there were serious exceedances in only 2 of those cases (Bawnmore GWS –
e.coli and nitrates and Listerlin GWS – e.coli).
The EPA regards Kilkenny’s private Group Schemes’ overall compliance with the Drinking
Water Regulations as being satisfactory in 2005. It noted that 7 of the 35 schemes monitored
were contaminated with E.coli. This was, however, “a significant reduction in the number of
schemes that were contaminated compared to 2004 when 28 of the 33 private group water
schemes monitored were contaminated” (EPA 2007, p.77.). The EPA did, however, express
concern that 7 schemes exceeded the Nitrate chemical parameter (an increase from 4 schemes
in 2004). They stated that “this trend is worrying and must be addressed by the sanitary
authority”(ibid). Kilkenny County Council have advised the Department that nitrates are their
biggest problem at the moment and this will need to be addressed. One scheme was tested for
THMs in Kilkenny in 2005 and was found to be compliant. Although, Kilkenny’s compliance
with the Drinking Water regulations is improving, the test results of the schemes upgraded
using Disinfection/Sterilisation during 2003-’06 means that a conclusion cannot be reached as
to the effectiveness of this water treatment solution.
.
135
Louth County Council
Eight of the nine Group Schemes in Louth requiring a water quality upgrade were treated
using the disinfection/sterilisation solution. Louth County Council provided expenditure data
and 2006 water quality test results in relation to those eight schemes. The efficiency and
effectiveness of these eight schemes are considered below.
Efficiency
As can be seen from the table below, the disinfection/sterilisation water treatment solution is
relatively cost efficient with the treatment cost ranging from €13 to €2,026 per house. The two
largest schemes Ballymakenny and Tullyallen had the cheapest treatment cost per house
because of economies of scale. Additional upgrade works were carried out, however, for 5 of
the 8 schemes. This increased the overall cost of compliance per house to between €861 and
€6,073 for these four schemes. It should be noted, however, that three of these additional
upgrades (Ballymakenny, Mountain Park and Sheepgrange) included source upgrades. The
Council said that they have no ongoing current cost commitments in relation to these Group
Scheme apart from the normal subsidy payment.
Table 4.4.6 – Louth Disinfection/Sterilisation Scheme Costs
Network/
Treatment Source*
No. of
Completion Solution
Cost (€)
Scheme Name Houses Date
Total
Treatment
Total Cost
Upgrade
Upgrade
Solution Cost per house
Cost (€)
Cost (€)
per House (€) (€)
20
Mar-06
40,518
0
40,518
€2,026
2,026
547
Dec-02
7,092
*463,866
470,958
€13
861
Waterunder
56
Feb-04
23,929
52,427
76,356
€427
1,364
Grangebellew
23
Sep-05
18,713
0
18,713
€814
814
Mountain Park
32
Feb-04
17,400
*176,939
194,339
€544
6,073
Sheepgrange
40
Jun-06
37,630
*187,499
225,129
€941
5,628
Tinure
23
Nov-04
18,831
0
18,831
€819
819
189
Jun-01
6,921
116,767
123,688
€37
654
Ardaghy
Ballymakenny
Drybridge/
Tullyallen
Source: Louth County Council 2007
136
Effectiveness
Table 4.4.7 – Louth Disinfection/Sterilisation Exceedances 2005
Water Supply Zone
Date
Parameter
Result
Units
Ardaghy
20-Jun-05 Coliform Bacteria
48
No/100ml
Ardaghy
12-Dec-05 Coliform Bacteria
200
No/100ml
Ardaghy
12-Dec-05 pH
6.2
Ballymakenny
29-Aug-05 Coliform Bacteria
1
No/100ml
Ballymakenny
12-Dec-05 Coliform Bacteria
13
No/100ml
Ballymakenny
12-Dec-05 Colony County at 22C
170
No/ml
Ballymakenny
29-Aug-05 E. coli
1
No/100ml
Drybridge/Waterunder
22-Aug-05 Coliform Bacteria
3
No/100ml
Drybridge/Waterunder
12-Dec-05 Coliform Bacteria
2
No/100ml
Drybridge/Waterunder
22-Aug-05 E. coli
3
No/100ml
Grangebellew
25-Apr-05 Coliform Bacteria
3
No/100ml
Grangebellew
12-Sep-05 Coliform Bacteria
6
No/100ml
Grangebellew
12-Sep-05 Coliform Bacteria
10
No/100ml
Grangebellew
3-Oct-05 Coliform Bacteria
2
No/100ml
Mountain Park
12-Dec-05 Coliform Bacteria
2
No/100ml
Mountain Park
12-Dec-05 E. coli
1
No/100ml
Sheepgrange
4-Apr-05 Coliform Bacteria
50
No/100ml
Sheepgrange
8-Dec-05 Coliform Bacteria
3
No/100ml
Tullyallen
26-Sep-05 Coliform Bacteria
1
No/100ml
Tullyallen
5-Dec-05 Enterococci
1
No/100ml
Source: 2005 EPA Drinking Water Report CD (2007)
As can be seen from Table 4.4.7 above, exceedances were recorded in 7 out of the 8 upgraded
schemes during 2005 (Tinure had no exceedances). 4 of those 7 schemes exceeded
microbiological parameters (e. coli and enterococci ) with the remaining 3 schemes exceeding
indicator parameters. In 7 out of the 8 schemes, Louth County Council identified inadequate
scouring of the pipe network as the major recontamination risk. This would seem to suggest
that the problem lies in the maintenance of the pipe network by the Group Scheme rather than
the effectiveness of the treatment solution itself
137
The EPA commented that Louth County Council carried out no monitoring of private water
supplies that supply water as part of a public or commercial activity in 2005. It also expressed
concern with the “drop in the level of compliance with the coliform bacteria parametric value
from 61% in 2004 to 50% in 2005 and coliform bacteria exceedances were recorded in 8 of
the 9 private group schemes monitored” (2007, p.83.) Four Schemes were tested for THMs in
2005 and no exceedances were found.
Table 4.4.8 - Louth County Council Update on 2006 Water Quality Test Results
Scheme Name
Microbiological
Indicator Exceedances
Recontamination Risk Issues
Total & Faecal Coliforms, pH,
Absence of scour valves and
Ammonia
dead ends in pipe network
Exceedances
Ardaghy
None
Ballymakenny
Enterococci
Total & Faecal Coliforms, Iron
Inadequate scouring of network
Drybridge /
None
None
Inadequate scouring of network
Grangebellew
None
Total Coliforms
Inadequate scouring of network
Mountain Park
None
Total & Faecal Coliforms,
Inadequate scouring of network
Waterunder
Clostridia Perfrigens
Sheepgrange
None
Total Coliforms
Inadequate scouring of network
Tinure
None
Total Coliforms
Inadequate scouring of network
Tullyallen
None
Total Coliforms
None
Source: Louth County Council 2007
In the 2006 water quality test results provided by Louth County Council in Table 4.4.8 above,
7 of the 8 schemes had exceedances. It is notable that Tinure had an indicator exceedance in
2006 even though it was fully compliant in 2005. Drybridge/Waterunder had no exceedances
in the 4 samples taken during 2006 even though it had an E.coli exceedance in 2005.
Ballymakenny had the only microbiological exceedance (Enterococci) in 2006 with the other
6 schemes reporting indicator exceedances. The evidence of the 2005 and 2006 water quality
test results for the completed Disinfection/Sterilisation schemes in Louth would suggest that
this solution has not been successful in sustainably ensuring compliance with the Drinking
Water Regulations. However, the fault appears to lie more in the maintenance of the pipe
138
network by Group Scheme volunteers rather than the robustness of the solution itself. Louth
County Council have advised the Department that they are currently meeting with Group
Water Scheme representatives in relation to the implications of the 2007 Drinking Water
Regulations and the need for proper operation and maintenance of Group Schemes.
Conclusions
Disinfection/Sterilisation appears to be a very cost efficient water treatment solution, where
the chemistry of the water permits it. However, the evidence of the Kilkenny and Louth water
quality test results on upgraded schemes casts a question mark over its sustainable
effectiveness. This is a matter for concern given that it is the water quality upgrade solution
selected for 122 Group Schemes (17% of the total). On the other hand, the positive test results
for the North Tipperary and Offaly schemes appear to indicate its effectiveness. The
explanation seems to be that the problem lies in the operation of the water treatment solution
by individual Group Schemes themselves rather than necessarily in the solution itself. The
Disinfection/ Sterilisation solution (and the non-DBO solution on a far smaller scale) are the
only water quality upgrade solutions, where responsibility for water treatment remains with
Group Scheme volunteers rather than professional technicians. The Department has tried to
encourage such Group Schemes to engage professional O&M contractors for this role by
offering a higher rate of domestic subsidy (€196.81 per house) for this purpose rather than the
basic €101.58 per house subsidy. However, the local authority questionnaire returns (Q26)
suggest that this higher rate of subsidy is not being claimed by Group Schemes. See domestic
subsidy section of this chapter.
The Disinfection/Sterilisation solution is in practice the pre-existing treatment solution for
many Group Schemes, which has been kept in place. It is attractive to Group Schemes as it is
cheap to operate and has minimal local authority involvement so the issue of local authority or
DBO plant water charges is non-existent. However, the status quo is unsustainable if many of
these Group Schemes continue to fail to comply with the Drinking Water Regulations. At a
minimum, local authorities must require Group Scheme members in non-compliant schemes
to participate in training programmes being run by the Water Services National Training
Group (WSNTG) or otherwise face prosecution for non-compliance with the Regulations. In
some cases, disinfection/sterilisation is only an interim solution as it only deals with
139
microbiological contamination. Therefore, it will eventually be superceded on some Group
Schemes by a more robust solution such as a DBO treatment plant.
The data examined shows no problems with THM exceedances but the statutory monitoring
requirements for this particular parameter, under the Drinking Water Regulations, are not as
onerous as for other parameters. Therefore, while there were no exceedances of THMs
identified for the above 4 counties, the proportion of schemes tested for THMs was quite
small. It might be prudent for local authorities to increase the level of testing for THMs for
Disinfection/ Sterilisation schemes, given the possible carcinogenic risk factors.
Finally, the issue of source protection was raised in the context of Kilkenny, where there is a
problem of nitrate contamination of groundwater sources. North Tipperary also mentioned the
need for aquifer protection measures to protect their Group Schemes’ groundwater sources.
As stated in the introduction, the use of the minimal disinfection/sterilisation treatment is
limited to Group Schemes where the raw water quality is quite high. If the quality of the
source water declines due to pollution of the source, the solution becomes ineffective and
more robust DBO treatment plants may need to be built in outlying locations, if connection to
the public mains is not technically feasible. The Department issued guidance to local
authorities on 31st July 2003 in relation to groundwater protection plans and the need to link
them to County Development Plans. It also suggests the creation of ‘Source Protection Areas’
around groundwater drinking water sources (Circular SP 5/03). However, only a limited
number of local authorities have adopted groundwater protection plans. There is already a
surface water source pilot protection project underway in Monaghan. The Department should
perhaps consider similar ‘low tech’ pilot approaches to source protection of groundwater,
where the water is only receiving minimal disinfection /sterilisation treatment.
140
Comparison of relative cost efficiency of Water Quality Upgrade Solutions
The relative efficiency of different water quality upgrade solutions is difficult to measure as
they are very varied in nature and as such reliable and meaningful comparisons are harder to
make. However, as grants are made on a cost per house basis, the relative cost of a number of
schemes from each upgrade solution are compared in Table 4.5.1 below. The DBO schemes
are part of the West Cavan and Mayo No. 1 DBO bundles. The upgraded Group Schemes
have been listed in ascending cost per house order with pipe network costs excluded.
In many respects, the exercise below bears out the conclusions of the previous two recent
reviews of the Water Sector discussed in the Literature Review i.e. 2002 Expenditure Review
and 2006 Fitzpatrick Associates NDP Review. It is actually very difficult to make
meaningful cost comparisons as individual water projects are by their nature unique.
A “distinct feature of the sector, which has very direct relevance to any evaluation that
addresses value-for-money issues, is that water infrastructure and plant is designed on a quite
bespoke basis for particular locations. In practice this makes benchmarking and cost
comparisons across projects and locations even within Ireland, never mind internationally,
difficult.” (Fitzpatrick Associates 2005, p.6.)
As can be seen from the table below, there are wide variations in the cost per house of
Schemes upgraded under the same solution never mind different solutions.
That said, certain patterns can be discerned. Generally, the disinfection/sterilisation solution is
by far the cheapest solution in cost per house terms and the DBO treatment plant solution is
the most expensive. Some of the DBO plants appear to have lower cost per houses, which
could be as a result of the economies of scale of the size of the schemes or the size of the
overall DBO Bundle. It must be remembered, though, that the DBO figures are provisional
due to the current lack of final accounts as these Schemes are only just completed. Therefore,
it is likely that the cost per house for DBO Schemes are actually understated as there are
outstanding Design Build costs yet to be included. Additional pipe network upgrade costs
have been excluded from the figures below for all solutions, as their inclusion would seriously
distort the exercise due to the widely differing densities of the areas served by individual
Schemes.
141
Relative cost efficiency of Water Quality Upgrade Solutions (Table 4.5.1)
No. of
Cost per
Scheme Name
Solution Type Houses Cost (€) House
Ballymakenny
Disinfection
547
7,092
€13
Tullyallen
Disinfection
189
6,921
€37
Maddoxtown
Disinfection
30
€1,200
€40
Caherlesk/Coolaghmore Disinfection
123 €12,000
€98
Windgap
Disinfection
55
€9,160
€167
Cloonminda
Takeover
54 €10,000
€185
Dunmore
Disinfection
30
€5,561
€185
Ballymack
Disinfection
68 €15,000
€221
Seskin
Disinfection
90 €30,000
€333
Cloonmore No. 1/Killilane CTPM
73 €25,200
€345
Bohola
DBO
574 €243,201
€424
Drybridge/ Waterunder
Disinfection
56
23,929
€427
Kilree Stoneyford
Disinfection
32 €16,100
€503
Mountain Park
Disinfection
32
17,400
€544
Newtown Kells
Disinfection
42 €25,000
€595
Bekan
CTPM
146 €100,000
€685
Grangebellew
Disinfection
23
18,713
€814
Tinure
Disinfection
23
18,831
€819
Sheepgrange
Disinfection
40
37,630
€941
Kilkerly
Takeover
46 €67,166 €1,460
Glencorrib
DBO
337 €516,317 €1,532
Kilmovee
DBO
523 €803,221 €1,536
Fahy Drumindoo
DBO
652 €1,110,293 €1,703
Adamstown
Non-DBO
3
€5,303 €1,768
Belderrig
DBO
55 €105,132 €1,911
Ballyglass/Carnacon
DBO
366 €731,109 €1,998
Ardaghy
Disinfection
20
40,518 €2,026
Lough Mask Creevagh
DBO
325 €675,623 €2,079
Kilmeena
DBO
320 €668,784 €2,090
Claren/Knocklehard
Non-DBO
232 €508,489 €2,192
Ballycroy
DBO
325 €750,404 €2,309
Ballagh/ Cahersherkin
CTPM
170 €411,214 €2,419
Corraleehan
CTPM
268 €653,759 €2,439
Killeen
DBO
208 €552,261 €2,655
Milltown
DBO
312 €989,837 €3,173
Glenhest
DBO
146 €481,465 €3,298
Kildallan
DBO
230 €776,705 €3,377
Brackloon/Spaddagh
DBO
150 €628,843 €4,192
Laghta
DBO
98 €513,039 €5,235
Cappanlea
Non-DBO
7 €37,000 €5,286
Ballymagovern/Corran
DBO
115 €609,185 €5,297
Glangevlin
DBO
145 €837,130 €5,773
Source: Local Authority and DBO Client Representative data – January 2007
142
Network Upgrades and Leakage Control
Introduction
It has been very noticeable from the examination of the various case studies that the cost of
network upgrades in many cases was equivalent to or exceeded the actual water quality
upgrade solution. In fact, expenditure under the network upgrade measure of €105 million
during the 2003-’06 Action Plan period was second only to capital expenditure on DBO
projects. It is important, therefore, to consider the value for money of this area of expenditure.
Expenditure trends and implementation
As can be seen from the table below, while 64% of the pipe network upgrades were carried
out on privately sourced Group Schemes, 36% of upgrades were for publicly sourced
schemes. It is also noticeable that 23% of the network upgrades were unrelated to water
quality upgrade works.
No. of Group Schemes receiving network upgrades 2003-‘06
Group Scheme pipe
network upgrades
Private Water Supply
Public Water Supply
Total
Unrelated to water
quality upgrades
2003
2004
2005
2006
Total
%
73
44
117
25
76
46
122
29
57
39
96
24
72
28
100
23
278
157
435
101
64%
36%
100%
23%
Source: Local Authority Questionnaires (Q25) – January 2007
Network upgrade data from the previous case studies of the different treatment solutions are
compiled in the table below in ascending cost per house order. The table shows that there is
no relationship between treatment solutions and the cost per house of network upgrades. The
use of cost per house to compare distribution networks unit cost is virtually meaningless as
the housing density pattern is unique from Group Scheme to Group Scheme. What this table
does show, however, is that network upgrades are quite costly so ensuring value for money is
vital.
143
Group Water Scheme
Name
Solution
Type
Tullyallen
Disinfection
Cloonmore No. 1/Killilane CTPM
Network
Upgrade/
Extension
Cost (€)
No. of
Houses
Network
Upgrade
Cost per
house (€)
189
€116,767
€618
73
€59,850
€820
Ballymakenny
Disinfection
547
€463,866
€848
Drybridge/ Waterunder
Disinfection
56
€52,427
€936
Seskin
Disinfection
90
90,000
€1,000
Erne Valley
DBO
1,011
€1,520,000
€1,503
Lavagh/Ballyheelan
Ballymack
DBO
Disinfection
369
€650,000
€1,762
68
165,000
€2,426
Newtown Kells
Disinfection
42
125,000
€2,976
Bekan
CTPM
146
€548,653
€3,758
Crossdoney GWS
DBO
255
€1,010,000
€3,961
Caherlesk/Coolaghmore
Disinfection
123
498,000
€4,049
Cloonminda
Takeover
54
€227,032
€4,204
Cappanlea
Non-DBO
7
€30,500
€4,357
Carrowmeena
CTPM
47
€215,975
€4,595
Corraleehan
CTPM
268
€1,234,405
€4,606
Sheepgrange
Disinfection
40
€187,499
€4,687
Mountain Park
Disinfection
32
€176,939
€5,529
Ballagh/ Cahersherkin
CTPM
170
€985,850
€5,799
Claren/Knocklehard
Non-DBO
232
€1,378,030
€5,940
Kilcredan
Non-DBO
54
€354,758
€6,570
Objectives of network upgrades
It is important to first remember that this was the original Group Schemes capital funding
measure, prior to the focus on water quality. Funds were used to build new Group Water
Scheme pipe networks to abstract raw water and transfer it to households. This funding
measure was also used to upgrade the pipe networks of existing Group Schemes. Since 2006,
new Schemes and scheme extensions have been funded under a separate capital measure. The
need to comply with the Drinking Water Regulations has given the network upgrade measure
an even greater significance. Although, network upgrades have nothing to do with water
144
treatment, they do play an important role in water quality upgrade solutions namely leakage
reduction and avoiding water recontamination.
Raw water re-contamination
Under all treatment solutions, the treated water is distributed from the Group Scheme or
County Council treatment facility to households via the Group Scheme pipe network. If,
however, there are any leaks or breaks in the pipe network, this can cause infiltration of the
water in the pipe network with external contaminants. Therefore, expenditure on treating the
water would be wasted as the water is re-infected in a sub-standard pipe network. In such
cases, it is necessary to repair or replace the sub-standard sections of pipe in order to remove
the risk of re-infection.
Unaccounted for Water (UFW)/Leakage
As was already discussed in the DBO section, water leakage or Unaccounted for Water
(UFW) is a major issue in the Group Scheme sector. Studies, such as the Mayo No. 2 Leakage
Control Strategy, have shown that bursts and leakage represent the single largest component
of Unaccounted for Water (March 2005, p.5). DBO treatment plants are built with an
allowance for 25% UFW. That means that 25% of the water coming out of the treatment
facility is lost through leaks and wastage in the pipe network. However, as has been seen, the
majority of Group Schemes have UFW well in excess of 25% and would not be able to supply
adequate levels of treated water to Group Scheme without eating into their additional
development design capacity for 2020. This is unsustainable for Group Schemes from a
development and economic perspective. If the Group Schemes are already using up their
water allowance for additional development to meet existing water demand , then that
development will not be able to take place as there will be inadequate water supply due to
excessive leakage.
More importantly, from the perspective of existing Group Scheme members, this level of
water wastage is financially untenable. The DBO plant operator charges for all the water that
is treated and piped out to Group Scheme networks. If 50% of that treated water is lost in the
pipe network, that is Group Schemes’ problem not the DBO operators as their responsibility
ends once the water enters the Group Schemes’ pipe network. In many cases, the DBO plant
145
operation and maintenance (O&M) charge bills are only now issuing to Group Schemes for
the first time. Several of the DBO Client Representatives have predicted that many Group
Schemes with high UFW/leakage levels will get a shock when they receive their first bills
from their DBO operator. Similarly, if a Group Scheme is receiving water from a public water
supply, the Council charge them for all water supplied to the Group Scheme, although allow
for 25% UFW. Any UFW in excess of 25% has to be paid for by the Group Scheme. A 25%
UFW allowance may appear quite high but “it is unrealistic to expect any buried system to be
leak free due to the many factors affecting the system” (Mayo Bundle 2 Leakage Control
Strategy – March 2005, p.8.).
Implications for the State
It could be argued that high UFW and the consequent level of DBO O&M charges or Council
water charges are a matter for Group Schemes rather than the State. However, all Group
Schemes domestic consumers receive an annual subsidy from the State towards the O&M
cost of being supplied with treated water. If the DBO O&M costs or County Council water
charges become too high due to excessive leakage in Group Scheme networks, Group Scheme
members will inevitably look to the State and taxpayer to provide higher subsidies. UFW is
also a major issue on public schemes but is not a major political issue as domestic consumers
are not paying directly for water services, which are funded through central taxation. As it
happens, “a €118m [public] project to repair and replace over €280km (174 miles) of leaky
water pipes in the Dublin region , saving 20 million litres of water per day, is to get under
way this summer” (Irish Times, 26th March 2007).
In some cases, the level of UFW could be so high that a treatment plant could not be brought
into operation as it would not be able to treat sufficient water to supply the Group Scheme,
even using up its additional development capacity. In such cases, untreated water would have
to continue to be abstracted from sub-standard existing sources. So there would be a major
problem of security of supply and the environmental cost of over-abstraction of water.
Therefore, the State would have built an expensive treatment plant, which could not be used.
The Department has addressed this issue by approving Advance DBO works, where critical
mains are replaced in cases where the level of leakages and bursts are too high to allow a
treatment plant to become operational. This is now a separate capital measure to network
146
upgrades. The Department has allocated €35 million towards Advance DBO works over
2005-’06. As already discussed in the DBO section, the Leakage Control Studies carried out
for Mayo and Galway by Ryan Hanley consultants provided clear evidence that leakage
control is more economical than adding plant design capacity (Mayo DBO Bundle No. 2 –
Leakage Control Strategy-March 2005).
There are also clear environmental benefits from reducing UFW through leakage control.
“Excessive abstraction of water may impact on the natural environment if it exceeds limits
necessary for compensatory flows to sustain the environment affected by the source e.g. fish,
flora, fauna. Excessive abstraction is also wasteful of scarce resources such as energy and
materials” used in abstracting and treating wasted water (ibid, p.11).
There are also clear potential savings for Group Scheme households from leakage control. In
the table below, Ryan Hanley calculate major savings in annual O&M costs for households by
reducing UFW to 20% for each of the Group Schemes below.
Mayo Bundle No. 1 – Potential Leakage Control Savings
Scheme Name
Potential 20%
No. of houses
Potential Annual
UFW Target
O&M Savings per
Saving (€)
House (€)
Ballycroy
€17,575
300
€59
Ballyglass/Carnacon
€27,905
366
€76
Killeen
€9,344
201
€46
Laughta
€4,221
77
€55
Glencorrib
€45,553
394
€14
Bohola
€8,176
574
€14
Lough Mask/Creevagh
€8,176
303
€27
Source: Ryan Hanley Consultants – March 2007
Location of Leakage and Metering
The location of leakage in a pipe network is a very important issue from the perspective of
paying for the leaking water and paying for its repair. If the leak is on the consumer’s
147
premises they pay for the leakage costs but if it is in the Group distribution system or cannot
be located, all Scheme members pay for it (Ardrahan Leakage Control Study 2006, p.9.).
Leakage Control studies carried out, as part of the Galway DBO Bundle No. 1, showed that in
some cases leakages are occurring excessively on either the consumer or the distribution side.
The studies were able to measure the source of water leakage on these schemes by
methodically isolating sections of the pipe networks using district meters and sluice valves
and measuring the water loss (Ardrahan Leakage Control Study 2006, p.10.). The
Department’s Inspectorate’s view based on experience to date of a broader range of schemes,
is that water leakage/UFW is occurring predominantly on the consumer’s side of the meter.
Scheme Name
Distribution leakage
Consumer leakage
Ardrahan
63%
37%
Rinn Killeeneen
13%
86%
Source: Galway DBO Bundle No. 1 – Leakage Control Studies 2006
There is, therefore, a strong financial incentive for Group Scheme members to have individual
metering of their connections particularly if they are required to contribute towards the
payment of large UFW bills to the DBO operator as part of their O&M charge. “The
installation of consumer meters should lead to a significant reduction in waste, as many
consumers will be unaware of what is a normal consumption for their premises should be.
The fact remains that without metering there is no incentive to conserve water and minimise
waste” (Mayo DBO Bundle No. 2 – Leakage Control Strategy-March 2005,p.13.).
The current position is that the Department 85% grant aids meters for domestic connections
on bundled DBO projects up to a maximum grant of €300 per domestic connection. Metering
on DBOs is recommended but not compulsory. These grants can be claimed under the
network upgrade measure. “In accordance with the Polluter Pays Principle, capital grants may
not be paid in respect of the provision of meters on non-domestic connections” (Circular
L11/2004). There is no grant aid available for metering under any of the other treatment
solutions. Metering is only funded on DBO bundles due to the high O&M costs to consumers
from high unidentified UFW levels.
148
Leakage repair cost – Efficiency and Effectiveness issues
The location of leakage is also vitally important from the perspective of repairing it in the
most cost effective manner. As already stated, it is clear from the examination of case studies
for each water quality upgrade solution that the cost of pipe networks network upgrades in
many cases was equivalent to or exceeded the actual water quality upgrade solution. While
the necessity of addressing leakages through network upgrades has already been considered at
length, it is important to ensure that network upgrade funds are being invested in the most
effective and cost efficient manner. In several cases, the whole pipe network was completely
replaced as part of the network upgrade works. In many cases, this may have been necessary
if the existing pipe work was originally badly laid or the pipe work had so badly deteriorated
that re-contamination of water or constant bursts were likely to occur. There is anecdotal
evidence, however, that some network upgrades were carried out without an evidenced based
investigation of where the main leakage problems in the network were located. A methodical
leakage control study as outlined above for Galway DBO Bundle No. 1 would ensure that
only those parts of the network, where leakages are definitely occurring, would need to be
replaced. There is also the issue of ensuring that the new pipe network is adequate for
meeting future hydraulic demand needs to avoid expensive pipe replacement works at a later
date.
Because of their experience in leakage control studies, Ryan Hanley were asked to comment
on the best way to ensure value for money in pipe network investment (Ryan Hanley
Submission, 14th March 2007 – Appendix 8). Ryan Hanley agreed with the current
Department policy of approving advance funding for the replacement of critical mains, with
clearly identified frequent bursts, prior to the start of DBO works. These Advance DBO
works should ideally include the installation of metering and water conservation
infrastructure. In the case of further network upgrades on DBOs or for the other water quality
upgrade solutions, a leakage control study should be carried along the lines outlined above to
ensure that the source of the leakage is scientifically verified. “This study will serve two
purposes namely

the identification of remaining network sections with excessive leakage together with
the names and location of consumers which are excessively wasting water

the on site hands on training of GWS personnel in the active leakage management”
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Ryan Hanley also advised that
“The design and construction of such rehabilitation works should be undertaken only on the
basis of full knowledge of the condition and performance of the existing network and with a
view to the future requirements for upgrading necessary to distribute the 2025 daily demand +
25%. It is recommended that such rehabilitation works should be sized using a hydraulic
model distributing above future design daily demands”.
The Department’s view is that is longstanding practice that local authorities should ensure that
network upgrades should only take place based on evidence based studies of leakage
problems and that such works should be properly hydraulically assessed. The Department
pointed to Circular L7/96 and the accompanying manual “Water Distribution Network
Management and Leakage Control” which provides guidance on “how to estimate UFW and
how to reduce leakage in a distribution network. If a comprehensive water audit has not been
carried out already, a preliminary audit should be carried out if it is suspected that the
proportion of UFW may be significant.” (Guidance Document for the preparation of a Rural
Water Strategic Plan, June 1999, p.2.5). The Department do concede, however, that as the
Rural Water Programme is a devolved local authority function, it is possible that in some
cases network upgrades may have occurred in the absence of such studies, as it is not the
Department’s role to verify this.
Conclusions
It seems clear from the above that the current levels of UFW, on Group Schemes, are
unsustainable from both an economic and environmental perspective. It has been proved that
investment in network upgrades makes good economic sense to reduce UFW and also to
remove the risk of recontamination of water in the network.
“Future levels of unaccounted for water in existing distribution networks are dependent on
both operational practises and investment in rehabilitation of the network. In the event that
no action is taken, there would be a progressive increase in unaccounted for water over time”
(Mayo Bundle No. 2 Leakage Control Study-March 2005, p.6.)
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It is also important however, that such upgrades are carried out in the most effective and cost
efficient manner. Network upgrade costs exceeded the actual treatment solution costs in many
of the water quality projects already examined in this chapter. The National Federation of
Group Water Schemes (NFGWS) has also predicted that the replacement of sub-standard
network will be the next big infrastructural challenge facing the rural water sector (Appendix
3). It is, therefore, recommended that revised guidance be issued to Councils in relation to
approving network upgrades. Such upgrades should only take place based on the results of a
methodical leakage control study. In addition, where substantial network upgrades are being
proposed, a hydraulic study should be carried out to ensure that the proposed upgrade will
meet the future requirements for 2025 demand+25% UFW. Finally, it is vital that universal
metering of all Group Water Schemes being upgraded under the Rural Water Programme be
considered as there is no incentive to conserve water or minimise waste without it. The
National Federation of Group Water Schemes (NFGWS) has expressed support for such an
initiative (Appendix 3). Quite apart from being a charging tool, meters are more importantly a
vital management tool for operating water distribution systems and identifying the precise
location of water leakages. Without such management information, it is comparable to
“attempting to run a national electricity grid without electricity meters” (NDP Evaluation of
Water Services 2005, p. 153.)
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Rural Water Subsidy
Introduction
The annual Rural Water Subsidy is the only contribution that the State makes towards the
domestic operational and maintenance (O&M) costs of running Group Water Schemes. It is
important to emphasise that this grant subsidises the water costs of domestic households only
and that there is no subsidy for non-domestic water consumers such as farms and other
commercial operations. Originally, the subsidy mainly covered the O&M costs of maintaining
pipe networks but in recent years, most of the O&M costs have related to water treatment
costs. Annual expenditure under the domestic subsidy scheme (€8 million in 2006) is
relatively low by comparison to the capital works programme. However, the subsidy is an
ongoing cost to the taxpayer that will continue after capital works have been completed so it
is important that this area of expenditure is examined. Also, there are increasing demands
from the Group Schemes’ sector for subsidy rates to be increased due to increased O&M costs
on Group Schemes since the subsidy was last increased in 2000 (Rural Water News, Spring
2006).
Evolution of the Group Water Scheme Subsidy
In 1997, the Government abolished public water charges for domestic users and instead
funded the current cost of supplying treated water through the Local Government Fund
(LGF). In the interests of equity, the Government also introduced a subsidy payment to Group
Scheme households to cover the operating cost of providing for their domestic water needs.
This subsidy is also funded through the Local Government Fund. The original 1997 subsidy
rates were £75 (€95.23) for each house supplied from a private source, and £35 (€44.44) for
each house supplied from a local authority source. The Minister increased the subsidy rates to
their current level on 28th March 2000.
Current Subsidy levels
The subsidy is paid directly by local authorities to Group Schemes on the basis of expenditure
on the domestic element of the Schemes’ operational costs. The current subsidy levels are
100% of the qualifying expenditure as approved by the local authority, subject to a limit of:
€50.79 for each house in a Group Scheme supplied from a local authority source. In
this case, householders receive up to 50,000 gallons of treated water from the Council
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for free so there are no treatment O&M costs. The €50.79 per house subsidy rate is for
the O&M of the pipe network only.

€ 101.58 for each house in a Group Scheme supplied from a private source, where the
Scheme members are responsible for the O&M of both the water treatment facilities
and the pipe network.

€196.81 for each house in a Group Scheme where water disinfection and/or treatment
is provided under a Design, Build, Operate (DBO) contract or where the water
disinfection/treatment plant is operated and maintained by a contractor by way of a
bona fide Operational and Maintenance Contract. This higher rate is paid in
recognition of the additional costs involved in paying for a professional water
treatment service and also to incentivise Group Schemes to avail of such professional
services to guarantee drinking water supplies of adequate quality. This grant also
subsidises the O&M of the pipe network.
Subsidy Expenditure trends
As can be seen from the table below, annual current expenditure under the domestic subsidy
scheme is quite small relative to the capital expenditure measures for water treatment and
network upgrades. However, it must be remembered that this is an ongoing annual cost to the
taxpayer unlike capital investment in treatment plants with a 20 year design life. It is
noticeable, therefore, that there has been a 50% increase in annual expenditure under the
domestic subsidy scheme between 2003 and 2006.
Expenditure on Domestic Subsidy 2003-‘06
Expenditure (€ million)
2003
2004
2005
2006
Domestic Household Subsidy
5.305
5.276
7.141
7.957
Source: Department of the Environment, Heritage and Local Government
It is likely that this increase in overall subsidy expenditure is due to the increasing number of
Group Water Schemes in receipt of the higher €196.81 per house subsidy rate, where water
treatment is provided under a Design, Build, Operate (DBO) contract. Councils also permit
Group Schemes to make back subsidy claims for several years, in recognition of their limited
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voluntary administrative resources. This back claim facility can cause annual expenditure
figures to fluctuate from year to year. The number of Group Water Schemes claiming the
annual subsidy, under the different categories, is set out in the table below
Number of Group Water Scheme claims per subsidy category
No. of Group Water Schemes claiming Subsidy
2003
2004
2005
2006
Public GWS Subsidy (€50.79 per house max.)
Private DBO Subsidy (€196.81 per house max.)
Private Non-DBO subsidy (€101.58 per house max.)
Total
128
23
520
671
130
24
518
672
111
27
467
605
82
33
316
431
Source: Q. 26. Compiled from Local Authority Questionnaire Returns 2007
Administration of the Subsidy Scheme
Councils pay the domestic subsidy to individual Group Schemes on foot of claims with
supporting documentation, verifying their O&M expenditure. Councils receive an annual
subsidy allocation from the Department, which is recouped throughout the year. The
Department has issued an Explanatory Memorandum to Councils, which provides guidance
on the operation of subsidy scheme. The Memorandum states that
“Where water supplied by a Group Scheme for non-domestic purposes is metered,
expenditure should be apportioned by reference to metered usage. In cases where usage is not
metered , operational expenditure may be apportioned on the basis of a standard allowance
of 50,000 gallons per house per year. Group are also permitted, as an interim measure to
apportion usage on the basis of the ratio of the number of domestic to non-domestic
connections. For the purposes of apportioning costs and the more effective application of the
polluter pays principle, local authorities may require that supplies of water for non-domestic
purposes be metered” (Department for the Environment, Heritage and Local Government
2002, p.6.)
Rural Water Liaison Officers were asked how they, in practice, distinguish the domestic from
the non-domestic element of O&M expenditure in order to recoup the appropriate subsidy to
the Group Scheme. Council responded that they generally apportion the O&M costs based on
the proportion of non-domestic connections on the Group Scheme. This apportionment
approach is quite rough and does not relate to actual water usage. It is possible, therefore, that
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some non-domestic Group Scheme members may be relatively heavy water users and may use
up a disproportionate amount of treated water. This could result in domestic users and
potentially the State subsiding non-domestic water users. This problem could be overcome
with the use of metered data on actual water usage for calculating subsidy payments but this is
not currently possible in many cases due to a lack of metering on many Group Schemes.
Case for subsidy increase
As already stated, there have been growing calls from the Group Schemes’ sector for
increases in the State subsidy in recent years. At its 2006 Annual Delegate Conference, “the
Board of the National Federation of Group Water Schemes (NFGWS) has been mandated to
secure a subsidy review that reflects the massively increased costs on group water schemes
since 2000, the last occasion on which subsidies were reviewed” (Rural Water News, Spring
2006, p.1.). It is certainly true that subsidy levels have fallen in real terms since 2000, as there
have been no increases to allow for inflation. There is also evidence from the early O&M data
available for the recently completed DBO treatment plants that the O&M charges per house
frequently exceed the €196.81 per house maximum subsidy level. More definitive operational
and maintenance data is required to confirm this.
This annual domestic subsidy is supposed to cover both water treatment and pipe network
management costs. If all the subsidy is spent on water treatment, there are no funds remaining
for management of the pipe network. This study has already identified that poor maintenance
of pipe networks by Group Scheme volunteers creates a risk of re-infection of water in the
pipe network. The NFGWS is seeking to “secure an increase in subsidy support that takes into
account two factors: 1. the cost associated with water treatment and 2. management costs”
(NFGWS Strategic Plan 2006-’08, p.9.). The NFGWS is also calling for paid managers and
staff to operate Group Schemes on a part-time or full time basis (Rural Water News-Autumn
2006, p.1.). The NFGWS certainly have a case for requesting a subsidy review but there are a
number of issues that the Department must consider in carrying out such a Review.
Cost Issues for Department
This Review has already identified certain issues impacting on the O&M costs of Group
Schemes.
155

There is evidence of significant non-domestic water usage by Group Water Schemes
based on the number of connections and water usage data (see Appendix 6). However,
metered water usage is often not used in calculating Group Scheme subsidies. It is
possible that there could be cross-subsidisation of non-domestic water usage through
the domestic subsidy.

There are already high levels of leakage/UFW on Group Schemes, which are pushing
up O&M costs for domestic and non-domestic users. The Department could not
possibly justify subsiding UFW in excess of the 25% guidelines through increased
domestic subsidies.
Policy objectives
Two of the eligibility conditions for the Group Scheme subsidy are that it is providing a
supply of water for domestic purposes that in the opinion of the local authority, is satisfactory,
and that water conservation measures are being actively implemented. It is not clear how
strictly these conditions are currently being enforced. It appears that many Councils have not
been overly rigorous in enforcing these conditions because of the need to win Group
Scheme’s co-operation in upgrading their water supplies. This is regarded as a pragmatic
approach as some Group Schemes have simply withdrawn from claiming subsidy as they
have no interest in upgrading their water supplies. Some Councils, on the other hand, do not
pay subsidies to Group Schemes that are not co-operating with the Rural Water Programme.
Another of the eligibility conditions for receiving subsidy is that Group Schemes must adopt
the Charter of Rights and Responsibilities for Consumers on Group Water Schemes compiled
by the National Rural Water Monitoring Committee (NRWMC) in 2002. “The European
Commission is concerned that individual group scheme consumers should have access to a
transparent and practical means of having genuine complaints listened to and acted upon by
those responsible for their water supply. The Charter of Rights is seen as a guarantee of
consumer rights in this regard” (NRWMC 2004, p.9). Anecdotal evidence would suggest that
the Charter of Rights is not always being actively implemented across the Group Scheme
sector. Some Councils have expressed the view that domestic consumers are subsidising the
cost of water usage by non-domestic consumers on Group Schemes. As the domestic subsidy
156
is being paid to the Group Scheme rather than individual householders, local authorities must
ensure that there is transparency in how Group Schemes operate and that the domestic
consumers benefit solely and fully from the domestic subsidy.
The major policy focus, at the moment, is on ‘end of pipe’ solutions to tackling drinking
water quality. In other words, treating the water after it has become contaminated. There is a
growing consensus on the need to “move beyond the present focus on end-of-pipe solutions to
providing sustainable quality water supplies through an increasing emphasis on source
protection and water conservation” (NFGWS 2006, p.1.). In other words, focusing on
prevention rather than cure. Several Councils already offer guidance to Group Schemes on
best practice in relation to source protection and the ongoing National Pilot Source Protection
Study in Churchill/Oram, Co. Monaghan is likely to propose some practical source protection
measures. Some Councils have suggested, in their questionnaire responses, that subsidy
payments should only be paid to Group Schemes, which have active source protection
measures in place. The NRWMC’s Charter of Rights contains a section on source protection
and states that
“It is the responsibility of suppliers of drinking water to protect drinking water sources and to
take necessary preventative and /or remedial action as appropriate. The public generally, and
in particular consumers of a local supply, should be aware of the risks of contamination and
should act to protect drinking water sources.” (NRWMC 2004, Appendix 1, p.25.)
Conclusion
The subsidy is a relatively small component of the Department’s budget for the Rural Water
Programme. However, it is an ongoing current cost commitment so it is important to
implement safeguards to ensure that the funding is used solely for the purposes intended i.e.
domestic water users only. Preliminary DBO O&M treatment cost data and the need for a
more professionalised approach to pipe network maintenance suggest that the Group Scheme
sector have a case for seeking a review of current subsidy rates. However, any decision to
increase rates must be based on a rigorous study of metered water usage data to ensure that
the Department does not in any way subsidise non-domestic water consumption or UFW
leakage levels in excess of the 25% limit. It is accepted that this may pose difficulties as many
Group Schemes are not metered and the Department only grant aids individual domestic
157
connections on DBO schemes. County Councils must also ensure that the achievement of
policy objectives such water conservation, water quality and transparency for Group Water
Scheme members, as already required under the existing subsidy scheme, are being
implemented by Group Schemes. There is also a need to link the payment of subsidies to the
active implementation of source protection measures by Group Schemes to protect their
drinking water sources from contamination.
158
New Group Schemes
Given the level of capital expenditure that has been invested in ‘end of pipe’ treatment
solutions for substandard Group Schemes over the 2003-’06 period, it is vital to ensure that
this problem does not recur. The principle of prevention rather than cure has to come to the
fore. The first question that needs to be asked is whether any more new Group Schemes
should be funded. In fact, given that the State will be legally accountable for any Group
Schemes falling within the criteria of the Drinking Water Regulations, it has to be questioned
whether any new Group Schemes should be permitted under the new statutory licensing
system. The first thing to do is to consider what has been happening under the New Schemes
measures during the 2003-’06 period. Up to 2006, new schemes were not in fact a distinct
spending measure so Councils simply funded new schemes from the Upgrade measure. In
2006, the Department allocated €9 million funding for new Schemes as a separate measure
from an overall budget of €113 million i.e. 8% of overall funding. There is, however, no
separate expenditure outturn figure available for 2006 as it is still recorded as part of the
overall 2006 Upgrade expenditure figure of €29 million.
Implementation of New Schemes
Councils were asked to provide details on new Schemes built in the table below. It should be
borne in mind that many of these schemes are quite small and will not be required to meet the
criteria of the Drinking Water Directive.
No. of new Group Water Schemes constructed 2003-‘06
New Group Water Schemes
2003
2004
2005
2006
Total
%
Private Water Supply
71
44
30
27
172
28%
Public Water Supply
131
118
101
88
438
72%
Total
202
162
131
115
610
100%
constructed
Source: Q.23 on Local Authority Questionnaire Returns 2007
The Questionnaire data indicates that 72% of the 610 new schemes constructed during the
2003-’06 period, were built with a connection to the public water supply. The number of new
Group Schemes built with private water sources declined each year. This is a very
159
encouraging sign as the EPA has identified Group Schemes with private sources as being the
main risk factor for water quality problems.
No. of existing Group Water Schemes extended 2003-‘06
Group Water Schemes
2003
2004
2005
2006
Total
%
Private Water Supply
15
19
13
21
68
63%
Public Water Supply
10
15
7
8
40
37%
Total
25
34
20
29
108
100%
extended
Source: Q.24 on Local Authority Questionnaire Returns 2007
Only 108 Group Schemes were extended in size over the 2000-’06 period but worryingly 63%
of these were served by a private water source. If any new or extended scheme grows to
beyond 15 houses or connects in to a premises with a public or commercial function e.g. dairy
farm, then the water quality must comply with the parameters of the Drinking Water
Regulations and water treatment upgrades may be required.
Alternative approaches to privately sourced Group Schemes
That said, one has to also consider the alternative to privately sourced Group Schemes. As
already stated, the preference would be to have all communities absorbed or connected into
the public mains. However, that is not economically viable for many existing small and
geographically remote communities. The only alternative for many of these schemes is to
either abstract water from a surface supply or more usually to drill a well. Wells do not come
within the remit of the Drinking Water Directive so there is little liability for the State for
their water quality. However, excessive wells do have environmental impacts and increase the
risk of contamination. Therefore, the Department’s long standing principle has been to only to
make well grants where there is no local Group Scheme for a house to connect to. It would
seem, therefore, that while it is preferable to limit new Group Schemes with private sources to
a minimum, they cannot be totally abolished as it is preferable to have a group of houses
abstracting from the same water source than a number of sources. That said, precautions will
need to be taken to ensure that the optimum private water source in the area is selected to
reduce the risk of source contamination. The Group will also have to put active source
protection measures in place, including the possible designation of source protection zones
160
(Daly and Deakin 1995). Councils should carry out audits of New Schemes to ensure that
active source protection is ongoing, as a requirement for continuing capital and subsidy
funding.
Conclusions
If new Group Schemes are to continue to be approved, it is necessary to put additional
conditionality in place to ensure that the water quality issues do not recur in the future. It is
also essential that the future need for uneconomic water treatment infrastructure is reduced.
Finally, Group Schemes should not be used as a vehicle to support unsustainable rural
housing patterns as small new schemes could eventually grow to become larger schemes,
which will need to be fully compliant under the Drinking Water Directive with the need for
additional costly treatment infrastructure.
Therefore, the following measures are recommended:
1) New Group Schemes should only be licensed in areas where it is verified that they are
compliant with local authorities’ County Development and Local Area Plans for
housing development.
2) All new Group Schemes approved must be connected to the public mains or an
existing DBO treatment plant, where it is technically and economically viable to do so
under existing grant limits.
3) New Group Schemes with private sources should only be licensed where there is no
other viable drinking water solution for existing houses.
4) New Group Schemes with private sources should not be licensed unless a
comprehensive risk assessment of alternative water sources, and the optimum water
source has been selected.
161
5) Active local source protection measures must be put in place for new Schemes, which
can be verified by Councils on an audit basis as a condition for continued subsidy or
capital funding.
A review of the New Schemes grant measure is vital to ensure that the water quality problems
of the past do not recur. The focus has to move from expensive ‘end of pipe’ solutions to
source protection. While the State currently has a legal obligation and financial imperative to
provide expensive treatment solutions for existing geographically remote communities, the
taxpayer cannot be reasonably expected to fund future remedial treatment infrastructure on
new Group Schemes with water quality problems in new housing settlements. If such
measures are not implemented, it is likely that the problems of the past could recur with
substantial financial consequences for the taxpayer.
162
Chapter 5
Future Funding Needs/Alternative Approaches
163
Terms of Reference No. 6
Evaluate the degree to which the objectives warrant the allocation of public funding on a
current and ongoing basis and examine the scope for alternative policy or organisational
approaches to achieving these objectives on a more efficient and/or effective basis.
Future Funding Commitments
It is clear from the June 2006 Report to the European Commission that there is still
considerable work to be done, which will require capital funding. Although, the bigger
schemes have been identified, there is still uncertainty with regard to the number of smaller
Group schemes serving a commercial or public function. Councils were asked to identify such
schemes as part of the data collection for the June 2006 Report to the European Commission.
Some schemes were identified but it is believed that a significant number of others exist.
One of the difficulties is that commercial or public function is not specifically defined under
the Drinking Water Directive or Regulations. The EPA did, however, issue a guidance
circular (DW 01/06) in relation to this on 11th May 2006 and included dairy farming and food
production as commercial functions. Given that Group Schemes are located in rural
agricultural areas, it is fair to assume that there are a considerable number of small Group
Schemes with connections to a dairy farm. It is imperative, therefore, that local authorities
identify such Group Schemes in their area so that upgrading solutions can be identified and
put in place.
As previously stated, there is also a significant amount of capital work ongoing in relation to
building new Schemes and extending existing Schemes. Any of these Schemes eventually
falling within the criteria of the Drinking Water Regulations will also need to be upgraded if
their water quality is not compliant with the Regulations. As stated earlier, it is important to
minimize the number of new schemes with private sources and investment in source
protection will be necessary to avoid considerably more investment in end of pipe solutions in
the future.
164
The existing level of subsidy payments to the Group Schemes sector will have to remain in
place for the foreseeable future unless there is a Government policy change in relation to
water charging for domestic consumers on the public mains. Subsidy levels have not been
increased since 2000 so have in fact fallen in real terms. The NFGWS have made proposals
for subsidy increases on the basis that declining volunteerism will involve paying caretakers
for the operation and maintenance of Group Scheme pipe networks. However, subsidy
increases cannot be considered unless there is rigorous analysis to ensure that existing subsidy
payments are not subsidising non-domestic consumers. The levels of UFW on many Group
Schemes is also extremely high so it should be assessed whether it would be more sustainable
to make greater investment in leakage control measures and metering than increasing the
subsidy.
That said, it is clear from talking to Federation and Council officials that the general decline
in volunteerism in Ireland is reflected in the Group Scheme sector. Many Group Schemes are
now run by a small number of long serving members, many of whom are relatively elderly. It
is likely that many Group Schemes in the future will not be able to operate without
professional managers. Alternatively, many of these schemes will have to be taken over by
local Councils. A wholesale ‘nationalisation’ of the Group Water Scheme sector would
inevitably result in significant cost increases to the taxpayer as many Group Water Schemes
are currently operated on a voluntary basis and would be replaced by professional local
authority technical staff in the event of takeover. Whatever the outcome, it seems clear that
the State is going to have to make an increased investment in the operating costs of Group
Schemes in the years to come.
Alternative policy approaches
Given the increased cost of the Rural Water Programme and the legal pressures to comply
with the Drinking Water Regulations, it is important that the Department considers alternative
policy approaches to try and implement the programme objectives in a more effective and
cost efficient manner. Some of these options are considered below.
165
Administrative arrangements
The last review of the Group Water Schemes Programme in 1989 looked at the administrative
arrangements for the Group Schemes’ sector and considered a number of alternative
organisational approaches ranging from central administration to full devolution of the
programme to local authorities (Department of Finance, 1989). The 1989 Report concluded
that the Programme should continue to be centrally administered by the Department. The
Programme was subsequently devolved to local authorities in 1997 with the Department only
making annual block grants and recouping claims from local authorities. Councils are now
solely responsible for the selection and technical assessment of schemes for grant purposes.
The Department funds a Rural Water Liaison Officer post in each Council to administer this
role. Given the significant increase in capital funding for the Rural Water Programme over the
2003-’06 period and the implementation problems that have been encountered, it is an
appropriate time to review the current administrative arrangements for the Programme.
The options essentially are that the programme should continue to be run by local authorities
or alternatively be transferred back to Departmental control. Given the current urgency to
upgrade Group Schemes, it is questionable whether there would be any added value in recentralising the administration of the programme. In fact, any radical administrative changes
during this critical period would be likely to disrupt rather than improve programme
implementation. As can be seen from the table below, there is a relatively small number of
staff in the Water Services Infrastructure Section currently working on the Rural Water
Programme. One Assistant Principal with five support staff and a single Engineering
Inspector are assigned to this area. They have responsibility for administering the block grants
to local authorities for upgrading the 729 Group Schemes as well the devolved Well grants
and the Small Public Schemes measures, which are not being reviewed as part of this report.
Breakdown of staff in Department’s Water Services Infrastructure Section 2007
Public Schemes
Devolved Rural
Programme
Water Programme
Administrative Staff
25
6
Technical staff
10
1
No. of Schemes
889 public schemes
729 Group Schemes
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There are significantly more administrative and technical staff involved in running the nondevolved Public Schemes Programme, where individual Water and Sewerage Scheme
proposals are appraised, approved and over seen by Departmental staff. In the event of recentralisation of the administration of the Rural Water Programme back to the Department, it
is clear that substantial new administrative and technical staffing resources would be required
within the Department. Vital local knowledge would also be lost as Departmental staff could
not possibly match local authorities’ knowledge of situations on the ground. The diversity and
community nature of the Group Schemes Programme means that it is best administered on a
local authority basis by a cohort of dedicated Rural Water Liaison officers and should remain
so.
The implementation problems to date cannot be ignored though and greater monitoring of
local authority activity is required. Councils currently provide six monthly reports to the
Department under the NDP but much of this data is of an expenditure nature. Councils should
be required to provide the Department with management data on physical progress to date
preferably on a six monthly or at least on an annual basis. Examples of such data are detailed
in Chapter 6 on Performance Indicators. The Department should be monitoring this data to
ensure that priorities are being addressed and that Departmental resources are being allocated
in an efficient and effective manner. It is noticeable that progress on the DBO element of the
Rural Water Action Plan has been quite strong even though this is the most complex element
of the Programme. The Department appointed a National Co-ordinator on a temporary
contract to oversee this element of the Programme and to liaise with local authorities and the
DBO project managers (DBO client representatives). It should be noted that a new National
Co-ordinator was appointed in August 2006 but the post’s terms of reference have been
extended to overseeing the implementation of all treatment solutions and particularly the
Takeover and Connection to the Public Mains solutions. On balance then, it is recommended
that the current organisational and administrative arrangements for the Rural Water
Programme remain in place.
Cost of Compliance
The significant capital investment of recent years in the Rural Water Programme have been
almost solely dedicated to upgrading the sub-standard quality of drinking water in Group
167
Water Schemes through the installation of treatment infrastructure or connection to the public
mains. As has been seen from the case study section of this report, the cost per house of the
DBO solution, in particular, is quite expensive due to the dispersed nature of the rural
population in Group Water Scheme communities. The European Court of Justice (ECJ) will
fine the State if these schemes are not upgraded but should this cost fall on the taxpayer?
There are two alternatives to pass on the cost to either Group Schemes or local authorities.
Under the first option, the State could implement legal measures to pass on the cost of
upgrading schemes to the Group Schemes themselves. This could be justified on the basis that
the Group Water Schemes are essentially private enterprises set up, owned and run by Group
Scheme members. One could question why a taxpayer living in inner city Dublin should be
required to fund the upgrade of privately owned infrastructure in rural Ireland. On the other
hand, the historical reason why Group Schemes exist in the first place is that the State did not
make provision for the public supply of running water to many dispersed rural communities in
the 1960s, due to opposition from large farming interests because of the impact on local
authority rates. These communities had to make their own arrangements with limited State
grants and the modern Group Scheme movement evolved there from (Mary Daly, The Buffer
State, 1997, p.483-488.). What the Dublin taxpayer can take for granted required a huge
voluntary commitment by small local communities. Putting aside the equity argument, there is
also a question of practicality. Unpaid trustees generally run group Schemes on a voluntary
basis. The State could legally require Group Schemes to upgrade their Schemes from their
own resources but nothing would happen in most cases as many Group Scheme members
simply could not afford to 100% fund upgrade works (See NFGWS submission – Appendix
3) . The ECJ would impose its fines and the State would have to upgrade the schemes without
delay as it pays punitive daily fines as well as a lump sum fine for not upgrading the schemes
from the start.
The alternative option is to pass on the cost of compliance to County Councils as the
responsible sanitary authorities for the area. The reality here is that County Councils are
almost completely dependent on central government for capital funding purposes so schemes
would not be upgraded with similar consequences to the option already outlined above.
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Programme Implementation
So it would seem that the State has little option but to continue to fund the cost of compliance
from central taxation. The problem at the moment, however, is not the availability of funding.
It is programme implementation. As already outlined in the previous chapter, implementation
of public water supply solutions has been relatively slow. Councils have listed problems with
Group Scheme co-operation and a lack of statutory power to intervene in non co-operating
Group Schemes. It has to be accepted that a small minority of the Group Schemes’ sector do
not regard water quality as being a problem for them and have no interest in co-operating with
the Rural Water Programme particularly if it involves increased costs for it members. On the
other hand, the Drinking Water Directive was approved by the Irish Government in the EU
Council of Ministers and is now enshrined in Irish law as the Drinking Water Regulations.
Private entities cannot choose to ignore a significant piece of public health legislation and
State agencies have to implement it. Sanitary Authorities i.e. County Councils are legally
required to take prosecutions against Group Water Schemes, that fail to put a plan in place to
upgrade their drinking water supplies.
While Councils do have powers to take legal action against Schemes, there has been a
question mark over their powers to take follow up action. Most Councils have argued that
they are waiting for the Water Services Bill to be enacted. The Department brought forward
several sections of the Bill and enacted them as the Drinking Water Regulations 2007. While
the new licensing system will be enacted with the Water Services Act 2007, the new
Regulations now give Councils extensive statutory powers to carry out remedial works on
Group Schemes themselves, where necessary.
European Court of Justice case
These new powers for Councils are obviously not a panacea but there needs to be clear action
to try and deal with implementation issues otherwise the possibility of ECJ fines will become
a serious possibility (see Rural Water News–Summer 2006). As previously explained, such
fines would be likely to include a lump sum comprising the amount of money saved by a
State for not investing in the necessary water treatment infrastructure plus a substantial daily
fine i.e. >€1 million until such time as the Schemes are compliant with the Directive. These
fines would have to be paid out of central government resources in the first instance as neither
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County Councils nor Group Schemes would have the resources to do so, as already explained
above.
However, given that the implementation of the Rural Water Programme is devolved to
individual local authorities, it does not seem equitable to expect national taxpayers to have to
carry the burden of fines imposed due to a local infringement. This would be particularly the
case if fines were imposed due to the inertia of a small number of Councils in enforcing their
powers under the Drinking Water Regulations against non-cooperative Group Schemes in
their administrative area. It could be more equitable to sanction such Councils individually by
reducing their annual Local Government Fund allocation until such time as the fines are paid
off. The Department has already warned of the possibility of such sanctions against local
authorities in public fora (Athlone Seminar-June 2006).
Source Protection
One of the notable feature of the Rural Water Programme is that most of the capital
investment relates to ‘end of pipe’ solutions. In other words, the water is treated after it
becomes contaminated. All five treatment solutions are ‘end of pipe’ solutions. This raises the
question as to why this water has become polluted in the first place. The generally accepted
response to this is poor farming practices, run offs from septic tanks and inadequate protection
of water sources (EPA 2006, p.21.). The National Federation of Group Water Schemes
(NFGWS) itself concedes that ‘end of pipe’ solutions are not sustainable and that there needs
to be a greater emphasis placed on source protection (NFGWS 2006, p.5). Article 7.3 of the
EU’s Water Framework Directive states that “Member State shall ensure the necessary
protection for the bodies of water identified with the aim of avoiding deterioration in their
quality in order to reduce the level of purification treatment required in the production of
drinking water. Member states may establish safeguard zones for those bodies of water”. This
would appear to indicate that in the future ‘end of pipe’ treatment of polluted water may no
longer be regarded as sufficient and that member states will be legally required to ensure that
their water sources do not become contaminated in the first place. Therefore, the issue of
source protection of drinking water supplies is likely to come to the fore in the future. The
Department is currently working on a Master Plan to meet the requirements of the Water
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Framework Directive and specifically to produce River Basin Management Plans (RBMP) by
2009.
Local Authority Source Protection Initiatives
Councils were asked in the Questionnaire (Q13) to detail any initiatives that they have taken
to encourage Group Schemes to adopt source protection measures. Most Councils responded
that they have given Group Water Schemes information in relation to source protection best
practice. This issue is also discussed with Group Schemes when they are preparing Action
Plans to address water quality deficiencies on their Schemes. Cork (North Area) and Longford
County Councils require Group Schemes to have source protection plans in place as a
requirement for their annual domestic subsidy payment. In Cork County Council (South and
West Areas), areas around sources are fenced off, where possible, to exclude cattle.
Surrounding landowners are advised in relation to nutrient management near water sources
and lectures are given to applicants on water quality, under the Department of Agriculture’s
Rural Environmental Protection Scheme (REPS). Some Councils advise Group Schemes to
re-locate their water abstraction to more suitable entry areas and to keep buffer zones around
water sources clear of contamination. A small number of Councils have taken no initiatives
with Group Schemes in relation to source protection.
National Action Programme under the Nitrates Regulations 2005
The National Action Programme was jointly drawn up by the Department of the Environment,
Heritage and Local Government and the Department of Agriculture and Food to give effect to
the terms of the EU’s 1991 Nitrates Directive. It was launched in July 2005 and was
subsequently given legal effect under the Nitrates Regulations of 12th December 2005. The
Regulations places limits on the land spreading of fertilisers and livestock manure and creates
buffer zones from surface and ground water supplies. It is hoped that the implementation of
these measures by farmers will protect surface and groundwater supplies from
microbiological contamination from animal waste and from chemical contamination by
excessive nitrates from fertilisers. The problem of nitrates in source water supplies has
already been identified as a problem for the effectiveness of the disinfection /sterilisation
solution in Kilkenny. “High levels of nitrate in drinking water may induce ‘blue baby’
syndrome [methaemaglobinemia]” (EPA 2007, p.30.).
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Departmental Initiatives - Groundwater Protection
As previously discussed in the context of the disinfection/sterilisation solution, the
Department’s Spatial Policy section issued guidance to local authorities in July 2003, in
relation to the role of the planning system in protecting groundwater quality (Circular SP
5/03).
“This circular letter covers three main issues in relation to the role of the planning system in
ensuring that development proceeds in a manner that offers the best possible environmental
protection, including protection of groundwater quality. The three issues are:
(a) The need for more information within development plans on the location and potential
vulnerability of groundwater resources and for clear policies on how development in
different areas will be approached based on the available information.
(b) The need within the development control system to ensure that effective regimes for
the proper assessment of site conditions as well as the design, installation and
maintenance of on-site wastewater treatment and disposal facilities are put in place.
(c) The need for planning authorities to put in place appropriate monitoring and
enforcement mechanisms that ensure that those who carry out approved development
meet their obligations to adhere to the terms of planning permissions.”
In practice, this Circular advises Councils to identify key groundwater resources and develop
groundwater protection plans, which should be linked with the implementation of their
County Development Plans. This could involve identifying source protection areas around
key aquifers i.e. groundwater sources used for drinking water purposes and determining “the
appropriateness of various categories of development to areas that have different levels of
vulnerability in terms of groundwater contamination” (SP5/03, p.3.). Planning Authorities
should also seek to verify that single house effluent treatment systems e.g. septic tanks are
properly installed and maintained as a condition of planning permission and measures should
also be put in place to verify that these conditions are observed on an ongoing basis. Circular
SP5/03 is specifically referred to in the Guidelines for Planning Authorities on Sustainable
Rural Housing issued to planning authorities i.e. County Councils in April 2005 (Department
of the Environment, Heritage and Local Government 2005, p.36.) This circular makes some
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very practical and sound proposals in relation to source protection but it is advisory only and
has no legal effect. Several County Councils have not opted to adopt groundwater protection
plans. Anecdotal evidence would suggest that local concerns in relation to the impacts of such
environmental protection measures on planning permissions for rural housing has influenced
this. The Department may need to review its position in relation to this issue given the cost
implications of being legally required to install water treatment solutions on small Group
Schemes, with commercial connections e.g. dairy farms, where the drinking water quality has
declined due to local source contamination.
Departmental Initiatives - Surface Water Protection
There are currently no Departmental guidelines in relation to source protection measures for
surface water supplies i.e. rivers and lakes. The National Rural Water Monitoring Committee
(NRWMC) has commissioned the Centre for Freshwater Studies in the Dundalk Institute of
Technology (DKIT) to carry out a National Pilot Source Protection Study on the Churchill
Oram Group Water Scheme in Co. Monaghan. “After a full year of detailed monitoring, the
project has identified the nature of all the pollutants in Milltown Lake, source for the
Churchill & Oram Group Water Scheme. Low tech remedial solutions are shortly to be
introduced on sections of the lake catchment and intensive work is starting on farmyard and
septic tank surveys” (Rural Water News-Autumn 2006, p.7.) These remedial measures will
include readily available materials and technologies e.g. buffer strips, fencing, cattle drinkers,
tailored REPS and recommendations for improvements in farmyard practices” (National
Source Protection Pilot Project, Interim Report December 2006). DKIT is also currently
researching “the extent to which wetlands and biomass cultivation might help in preventing
run-off from agriculture and septic tanks into our waterways” (Ibid- Winter 2006, p.12.).
The septic tank survey is considered particularly significant given concerns expressed by
organisations such as An Taisce and the Geological Survey of Ireland (GSI), in relation to the
possible impact of runoffs from poorly maintained septic tanks on rural water sources
nationally (Daly, Donal, 2000, p.8.). It is estimated that there are approximately 300,000
septic tanks in the country and it is suspected that a significant number of these tanks may be
inadequately maintained. Analysis of the 2006 Census returns will provide more definitive
data on the number of septic tanks in the coming months. The results of the National Pilot
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Source Protection Study’s extensive septic tank survey may provide some firm data in
relation to the potential scale and impacts of this problem. The new Water Services Act makes
provision for local authorities to legally require the owners of septic tanks to properly
maintain their effluent treatment systems.
It is hoped that the outcomes of the National Pilot Study will produce a source protection
template for surface drinking water supplies in Ireland. It should be stressed, however, that the
quality of raw surface water is generally inferior to groundwater so successful source
protection measures are likely to reduce the level of water purification treatment rather than
remove the need for treatment entirely. Teagasc, the State’s farm advisory body, is also
currently looking at the practical application of measures under the Department of Agriculture
and Food’s Rural Environment Protection Scheme (REPS) to encourage intensive farmers to
implement source protection measures (Rural Water News-Autumn 2006, p.7.). As already
stated in the subsidy section, active and verifiable source protection should be linked to
subsidy payments in the future.
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Chapter 6
Proposed Performance Indicators
175
Terms of Reference No. 7
Specify potential future performance indicators that might be used to better monitor the
performance of future Action Plans for Rural Drinking Water Quality.
Introduction
The starting point in developing new performance indicators is to first examine the existing
monitoring system and review how the inputs, outputs and outcomes are monitored.
Grant Allocation/drawdown process
The inputs i.e. spending measures are set out in the table below. The Department makes an
annual block grant to each Council, participating in the Rural Water Programme, broken
down into the capital investment measures below. Councils select and prioritise the individual
Group Water Scheme works, to be funded from the various measures. Councils draw down
these capital grants from the Department during the course of the year, as expenditure is
incurred, so the Department is able to monitor expenditure under the various capital measures,
throughout the year.
Table 6.01 Annual Expenditure on Capital measures under the Rural Water Programme
Expenditure on Capital
Measures (€ million)
Design Build Operate (DBO)
DBO Advance Work
LA Takeover
2003
2004
2005
8.723
21.194
33.812
31.568
95.297
-
16.874
18.464
35.338
-
2006 Total
9.467
8.91
10.884
16.924
46.185
Upgrade of GWS networks
30.352
20.323
25.738
28.996
105.409
Connect to the Public Main
-
5.367
6.751
3.895
16.013
55.794
94.059
99.847
298.242
Total
48.542
Source: Department of the Environment, Heritage and Local Government
Expenditure reporting requirements
As part of National Development Plan (NDP) reporting requirements, Councils are required to
prepare six monthly expenditure returns for the Border Midlands West (BMW) Regional
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Assembly and Southern and Eastern (S&E) Regional Assembly. Some of this capital
expenditure is eligible to be recouped from the European Regional Development Fund
(ERDF). These returns are submitted in the first instance to the Department for onward
transmission to the BMW and S&E Regional Assemblies. The Department have developed an
excel based Management Information System (MIS) to record and process this six monthly
expenditure. It is broken down on a County Council basis with details on each Group Water
Scheme in receipt of capital funding. For each Group Scheme, the following indicator data is
recorded:

Population Equivalent (P/E) of Scheme

No. of house/farm/commercial water connections

Average Water Supply demand per day in m3 (cubic meters)

%Domestic/Non-Domestic Water demand
Expenditure reporting is broken down into the following categories.
Regional Assembly Reports
Expenditure Categories
Water Treatment/Disinfection
New Schemes/Scheme Upgrades
Takeover
Therefore, expenditure for each Group Scheme is recorded under one or more categories. For
example, a Group scheme, which receives a DBO treatment plant and a pipe network upgrade
would have expenditure recorded under both the water treatment/disinfection and New
Schemes/Scheme upgrade categories. It is also recorded whether the scheme is complete or
still work in progress.
It is clear to see that the annual capital allocation measures and the NDP reporting expenditure
categories do not match. There are only three expenditure categories for Group Schemes
under the NDP reporting system. Expenditure on DBOs and Disinfection/Sterilisation are
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recorded under the ‘Water Treatment/Disinfection’ heading. Expenditure on new Group
Schemes, pipe network upgrades and connections to the public mains are recorded under
‘New Schemes/Scheme Upgrades’. The 2000-’06 NDP reporting system was developed in
2000 based on the capital allocation measures for the Group Schemes Programme existing at
that time. Annual allocations were broken down into more specific spending measures over
subsequent years to target expenditure on priority areas. As a result, the NDP reporting
categories have become quite dated and while meeting NDP/Regional Assemblies reporting
requirements provide little in the way of substantial management information for current
needs.
Programme Output reporting requirements
The Department occasionally requests Councils to provide output data in relation to each of
the water quality upgrade solutions. This is generally required to update the European
Commission on progress with Group Schemes required to comply with the Drinking Water
Regulations. The last such report was the June 2006 Report to the European Commission on
Measures to bring Group Water Schemes into compliance with the Drinking Water Directive.
Progress under the five water quality upgrade solutions, are outlined below. Councils were
requested to provide a further update on progress in March 2007.
Table 6.02 - Implementation Status of Group Water Schemes by upgrade solution category
Treatment Solutions
DBO
Non-DBO
Connect to Public Main
Council Takeover
Disinfection/Sterilisation
Public Source
Total No. of Schemes
% implementation
% Solution In
Work in Upgrades Total
% Upgrades
breakdown Planning Progress Complete Schemes complete
35%
3%
16%
9%
17%
20%
100%
19
7
85
35
19
21
209
9
27
27
11
15
30
5
6
3
92
109
258
21
118
65
122
145
186
26%
298
41%
245
34%
729
12%
24%
5%
5%
75%
75%
Ref. Figures derived from June 2006 Report to the European Commission on Measures to bring Group
Water Schemes into compliance with the Drinking Water Directive
The first thing that is apparent is that there is a mismatch between the financial inputs and
physical outputs for the Programme. The non-DBO and Disinfection/Sterilisation treatment
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solution outputs do not appear in the list of annual allocation capital measures (inputs). This is
because they are financed out of the upgrade measure. This anomaly has been corrected in the
2007 allocations with a separate capital spending measure for Disinfection/Sterilisation
schemes. The non-DBO treatment solution generally involves an upgrade of existing water
treatment infrastructure on a small number of Group Schemes so it is probably appropriate for
it to be funded as part of the Upgrade expenditure measure rather than have its own dedicated
measure.
Non-Drinking Water Regulations related outputs
The other issue that needs to be considered is that this output progress report only looks at
Group Schemes, which require a water quality upgrade solution, in order to comply with the
Drinking Water Regulations i.e. Schemes>15 houses and Schemes with a connection to a
commercial premises or a premises with a public function. As has been seen from this VFM
Review, there are several areas of capital expenditure, which have no relationship to the
Drinking Water Regulations compliance. These measures are;
Non-Drinking Water Regulations related outputs
Funding Measure
New Group Water Schemes
New Schemes
Extensions to existing Group Schemes
New Schemes
Schemes taken over by Council
Takeover
Schemes connected to the public mains
Connection to the Public Mains
Pipe Network Upgrades
Upgrade of Group Water Schemes
The ‘Takeover’ and ‘Connection to the Public Mains’ measures are particularly problematic
as expenditure related and unrelated to achieving Drinking Water Regulations compliance i.e.
outcomes are mixed in together. Therefore, while there is currently a significant level of
expenditure and outputs under these spending measures, very little of this activity related to
achieving priority outcomes during the 2003-’06 period under review. Pipe network upgrades
is another expenditure area, which is related to different outcomes, and indeed is linked to all
treatment solutions as well. The Department instructs all local authorities to prioritise
Drinking Water Regulations Schemes for upgrades when submitting their funding bids for
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block grants. However, this is ultimately a matter for local authorities to implement as they
approve and advance the individual schemes rather than the Department.
Proposed new Measures structure
Therefore, expenditure and outputs related to different outcomes should be separated out to
give a true picture of implementation and achievement of priorities. The starting point to
improving performance monitoring is to change the way that capital funds are allocated in the
first place to try and match inputs to outputs to outcomes. This is, of course, only possible
Inputs -
Outputs -
Outcomes-
Spending
Completed
Objectives
Measures
Works
achieved
where your outcomes i.e. objectives are known. In the case of most of the Rural Water
Programme, this is clear cut i.e. compliance with the Drinking Water Regulations. In the case
of other works, the outputs are clearly definable but the objectives or certainly the
prioritisation of objectives is less clear. To date, the policy has been to set out programme
priorities and to ask Councils to only advance work for priority schemes. However, if there
are delays in progressing priority works, there is very little control to stop Councils from
instead spending funds on low priority works e.g. non-urgent Group Scheme takeovers and
connections to the public mains.
The proposed solution is to split the annual capital allocations into two main categories –
Works related and Works unrelated to compliance with the Drinking Water Regulations.
These two main allocation categories can then be split into sub-categories based on
programme priorities and objectives. The two proposed Measures structures are outlined in
turn below.
Drinking Water Regulations Measures Structure
This only includes capital allocations for Group Schemes, which require a water quality
upgrade solution, in order to comply with the Drinking Water Regulations i.e. Schemes>15
houses and Schemes with a connection to a commercial premises or a premises with a public
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function. In this case, the inputs will be the capital allocations made under the various
treatment solution measures. The outputs will be the completed treatment solutions and the
outcomes will be results of the water quality tests carried out by the local authorities, to
confirm compliance with the Drinking Water Regulations. The following is the proposed
system for monitoring these inputs, outputs and outcomes.
Proposed Allocations/Input Measurement
Capital allocations should match each of the five water quality upgrade solutions. The
Takeover measure should, however, be broken down into public source and private source
schemes. Analysis of Questionnaire returns from local authorities indicates that 65% of
takeover expenditure related to lower priority Group Schemes with public sources. The
European Commission is most concerned with the upgrade of private source schemes as these
present the greater risk to public health. Therefore, it is prudent to allocate takeover funds for
private and public source schemes separately to ensure that expenditure under these two
priorities can be tracked separately.
Allocations – (Drinking Water Regulations Compliance) Treatment Solutions
Allocation sub-categories
Allocation amount (€)
DBO
Non-DBO
Disinfection/Sterilisation
Connection to the Public Mains
Takeover (Private Source)
Takeover (Public Source)
Pipe Network Upgrade
Proposed Output Measurement
Councils should be asked at least once a year, but preferably every 6 months, to provide
output details of Group Scheme works in planning, work in progress or complete for each of
these measures as per the summary June 2006 Report to the European Commission. Schemes
would only be categorised as work in progress if the contractor has commenced work and
complete if the new water quality upgrade solution is fully operational. The only change from
the existing June 2006 Report output table would be to break the Takeover scheme outputs
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into the number of public source and private source schemes taken over, as the latter are the
priority Schemes.
Proposed Outputs Table
No. of Group Schemes (by
In
Work in
upgrade solution)
Planning
Progress
Completed Total
Design Build Operate (DBO)
Treatment Plant
Non-DBO Treatment Plant
Connection to the Public Mains
Local Authority Takeover
(Private)
Local Authority Takeover
(Public)
Disinfection/Sterilisation
Pipe Network Upgrades
(included in schemes above)
The only problem here is how to incorporate expenditure on pipe upgrades into the above
outputs model. It is possible that pipe upgrades could be carried out on any of the above
schemes in addition to the water quality upgrade solutions. The solution is to include an
additional row in the outputs table for the number of Group Schemes receiving a pipe network
upgrades in addition to their water quality upgrade. It is vital that basic pipe network upgrade
output data is recorded, as expenditure under this measure is second only to the DBO
measure.
When reporting to the European Commission, the Department has also reported outputs in
terms of households as well as Group Schemes. This is important to ensure that a distorted
picture of implementation is not presented due to the varying sizes of Group Water Schemes.
For example, in the table below, there are three Group Water Schemes of varying sizes. If one
was to measure completions purely on a Group Scheme basis, you would say that one out of
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the three Group Schemes is complete so you have 33% completion. Alternatively, you could
count completions in terms of
Group Scheme Name
No. of Households
Status
Group Scheme A
900
Complete
Group Scheme B
85
WIP
Group Scheme C
15
Planning
the number of households that have benefited from Scheme completions overall. This would
mean that 900 out of 1,000 houses have been upgraded i.e. 90% completion. It would be
generally be agreed that household completions give a more genuine measurement of
implementation. However, annual capital allocations (inputs) are made on Group Scheme
basis and the water quality i.e. outcomes is tested on a Group Scheme basis. Therefore, output
data should be provided by Councils on a per Group Scheme and a per household basis using
the proposed Outputs table format above.
Proposed Outcome Measurement
The objective/outcome of water quality upgrade works is to bring Group Schemes into
compliance with the Drinking Water Regulations. The measurement of this outcome is quite
clear cut as the quality of water coming out of household taps must meet the necessary
standards. As previously stated, local authorities are legally required to test the water quality
in Group Schemes and forward the results to the Environmental Protection Agency (EPA) for
publication in an Annual Report so the data is publicly available. The only problem is that
there is a significant time delay between testing and the publication of the results by the EPA.
For example, the most up to date EPA Drinking Water Report, based on 2005 water test
results, was published in January 2007. The Department needs far more recent test result data
than that to assess effectiveness of outcomes.
Therefore, for each completed Scheme above in the outputs table, Councils should be required
to report any exceedances of the Drinking Water Regulations’ parameters on at least an
annual basis. This places no additional administrative burden on local authorities as they are
current statutorily required to provide annual drinking water quality test results on all Group
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Schemes to the EPA by February of the following year. In other words, the test results for the
2005 EPA Drinking Water Quality Report published in January 2007, should have been sent
to the EPA by February 2006. Therefore, the test data results are already available in Councils
and can be used to complete the Exceedances table below. If no exceedances are reported for
a completed Group Scheme, the Council are, by default, confirming that that Group Scheme is
now fully compliant with the Drinking Water Directive.
Upgraded Group Schemes - Exceedances Report
Name of
Date
Upgrade
Microbiological
Chemical
Indicator
Remedial
Group
Completed
Solution
Parameters
Parameters
Parameters
Action
exceeded
exceeded
exceeded
Taken
Scheme
As has been seen from the analysis of various case studies under the different solutions, there
are still exceedances in the case of some Group Schemes even after they have been upgraded.
This calls into question the effectiveness of the treatment solution. In some cases, it needs to
be established whether the treatment solution is ineffective or whether the problem in fact lies
in the operation and maintenance of the Group Scheme by its volunteer members. It is not
possible to detect such problems unless there is timely test data available to Group Schemes,
local authorities and the Department. While it is the legal responsibility of the local authority
to resolve the water quality problem in conjunction with the Group Scheme, the Department
needs to be aware of such problems;

to identify if there is a problem with the effectiveness or sustainability of any of the
completed treatment solutions

to ensure that there is no public health hazard to water consumers

to ensure that the necessary remedial action is taken prior to the publication of the test
results in the EPA Drinking Water Reports

to avoid ECJ imposed fines for continuing to breach the terms of the Drinking Water
Directive
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The last point is the most significant from a value for money perspective. An ineffective
treatment solution not only means that the taxpayer’s money was wasted on that capital
investment, the taxpayer could also end up bearing the brunt of substantial EU fines, far in
excess of the treatment solution cost. The latest EPA Drinking Water Report was quite critical
of some Council’s water quality monitoring regimes. It found that no testing at all was done
on 9% of Group Schemes. As has been seen from this study, some Group Schemes are not
tested at all after they have been connected to the public mains, even though they are still
Group Schemes with independent pipe networks. The Minister for the Environment, Heritage
and Local Government has recently introduced new regulations giving additional powers to
the EPA to prosecute Councils not fulfilling their statutory duty to test all Group Water
Schemes.
Annual Output Statement
From 2007, Government Departments are required to produce annual output statements,
which set out annual output targets. These output statements are appended to the annual
Departmental Estimates, when submitted to the Oireachtas for approval. The Group Water
Schemes’ sector’s target is set out in the table below.
Performance Indicators
Output Target for 2007
Percentage of Group Water Scheme
85% of Group Water Scheme households
households in compliance with national
in compliance compared to 75% at the
drinking water standards at year end
end of 2006
As can be seen from the table, the performance target is actually an outcome target rather than
an output target. The Department will need to ensure that the information in the Exceedances
Report is taken into account as basing compliance on the number of upgraded Group Schemes
would be inaccurate unless it is verified that all of these Group Schemes are in fact compliant
after upgrading.
Identification of Group Schemes with a commercial function
As has been stated several times throughout this Report, the Drinking Water Regulations do
not just apply to Group Schemes with greater than 15 houses. It also applies to Group
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Schemes of any size with a connection to a premises providing a public or a commercial
function. For example, the non-DBO Cappanalea Group Scheme was required to comply with
the Regulations as it is connected to an adventure centre, although it only has 6 houses
connected to the Scheme. The EPA noted in its 2005 Drinking Water Report (January 2007)
that many County Councils had, in fact, not provided water test results for many such
schemes. It is important that Councils ensure that Group Schemes serving a public and
commercial function, as per the EPA (DW 01/06 of 11th May 2006) circular are identified and
upgraded, if necessary.
Other Allocations Measures
Introduction
This includes all capital measures, where compliance with the Drinking Water Regulations, is
not an objective (outcome). In other words, the Irish Government is not legally compelled by
the EU Drinking Water Directive to invest in the Other Allocations Measures so this is
discretionary capital expenditure. The first point to note, though, is that expenditure under
these measures may, in some cases, also have water quality objectives. For example, there
could be a small Group Scheme <15 houses with a polluted private water source. While this
Scheme is not required to comply with the Drinking Water Regulations, the Council may
quite justifiably decide to connect it to the public mains on public health grounds. It is
important to make this distinction from the outset as the allocations’ split is based on
Drinking Water Regulations upgrades and non-Drinking Water Regulations upgrades not
water quality and non-water quality upgrades.
Proposed Inputs Measurement
Capital allocations would be made based on the measures set out in the Other Allocations
structure table below. It should be noted that New Schemes, Scheme Extensions and
Takeovers are broken down into private and public source schemes. This reflects the reality
that private source schemes generally have worse water quality problems. Therefore, as
already discussed in the New Schemes section, it is important to monitor the development of
new Schemes and Schemes Extensions with private sources as they may need expensive water
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treatment solutions in the future if they expand and need to comply with the Drinking Water
Regulations i.e. > 15 houses or connect to a premises with a commercial or public function.
Allocations – Other (Non-Drinking Water Regulations Compliance) Measures
Allocation amount (€)
Allocation sub-categories
New Schemes (Public source)
New Schemes (Private source)
Scheme Extensions (Public source)
Scheme Extensions (Private source)
Scheme Takeovers (Private Source)
Scheme Takeovers (Public Source)
Connection to the Public Main
Pipe Network Upgrade
Proposed Outputs Measurement
Outputs should be measured by asking each local authority to complete an outputs table for
all the allocation sub categories as below.
Outputs Table
Allocation sub-categories
In
Work in
Schemes
Planning
Progress
Completed
New Schemes (Public source)
New Schemes (Private source)
Scheme Extensions (Public source)
Scheme Extensions (Private source)
Scheme Takeovers (Private Source)
Scheme Takeovers (Public Source)
Connection to the Public Main
Pipe Network Upgrade
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Councils will also have to complete an additional table (below) listing any Group Schemes,
which have fallen under the remit of the Drinking Water Regulations since the last Report.
These Group Schemes may require future treatment upgrade funding so this needs to be
flagged in advance. An exceedances report needs to be prepared for each of these Group
Schemes, which are non-compliant.
Name of New
No. of houses
Indicate whether
Public/Commercial
Group
in Group
Public or Private
Connection
Scheme
Scheme
Source
(Yes/No)
Outcomes Measurement
Measuring outcomes are problematic for the Other Allocations measures as in many cases the
objectives/outcomes of the capital investment are unclear. The last Review of the then Group
Water Schemes Programme in 1989 stated the two main objectives as being Water Quality
and Water Quantity i.e. “providing a sufficient quantity of piped water in as many houses as is
feasible” (p.2). The Review subsequently stated that “at present virtually all houses have a
piped water supply” whether from a Group Scheme or a single house source e.g. a well (1989,
p.25). The water quality objective has subsequently come to the fore and has been already
been discussed at length.
The expected outcomes/objectives from Other Measures with no connection to water quality
is less clear. Those measures are New Schemes, Extensions to existing Schemes and Pipe
network upgrades unrelated to water quality issues. Investment under these capital measures
is currently demand led by Group Schemes and County Councils. Group Schemes request
funding from County Councils who submit funding bids to the Department in support of their
block grant allocation. If the block grant allocation is large enough, then the Council approves
whatever works it wishes. The only Departmental constraint is that there is a 15% capital
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contribution from the Group Scheme and that the total capital works does not exceed €6,476
per house. As already stated in previous chapters, there is a need for greater guidance to
County Councils in relation to the approval of New Schemes particularly as these Group
Schemes could require expensive publicly funded water treatment solutions in the future, if
their growth is not regulated by the State. There also needs to be greater guidance in relation
to the approval of pipe network upgrades in the Other Measures category. Both sets of
guidance must clearly set out the objectives/outcomes required for public investment under
these Measures to ensure Value for Money for taxpayers.
Pipe Network Upgrades – Outcomes Measurement
As stated several times during this study, pipe network upgrades have been a very significant
element of expenditure under the Rural Water Programme over the 2003-’06 period. This
expenditure is largely explained by the need to reduce the levels of UFW in pipe networks.
Therefore, it logically follows that the Department and local authorities should set specific
UFW reduction targets as the outcome for pipe network upgrade investment.
Conclusions
On balance then, what are the advantages and disadvantages of putting in place a dual
allocations system with separate allocations for Group Schemes required and not required to
comply with the Drinking Water Regulations. The advantages are that :
1. There is a clear distinction made between discretionary and non-discretionary capital
expenditure. In other words, it is clear which capital expenditure the Irish Government
is legally compelled to make under the EU Drinking Water Directive and which
expenditure is at the discretion of the State. This is particularly important to know if
the Minister needed to target funding for diversion to higher priority areas in the
future.
2. The Department will be clearly able to track capital investment (inputs) to comply
with the Drinking Water Regulations to outputs (Scheme completions) to outcomes
(compliance with drinking water quality parameters). At present, this is not possible
with takeovers, connection to the public mains and pipe network upgrades for Group
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Schemes, with no compliance requirements, mixed into the same capital measures
(inputs) and outputs (completed schemes) data. Under a separate allocations and
outputs reporting system, the Department will have clear headline data for tracking the
achievement of different outcomes.
3. Councils will be prevented from diverting capital funds targeted at high priority
Drinking Water Regulations Group Schemes to non-Drinking Water Regulations
Schemes.
The disadvantages are that:
1. An already complicated system of capital measures becomes even more complicated
with even more splits into sub-categories. The counter argument to that is that the
expenditure will be better targeted with a more coherent match between inputs,
outputs and outcomes.
2. It could cause local authorities to underspend their allocations under certain measures
e.g. in cases where there were delays in progressing high priority Drinking Water
Regulations Group Schemes. However, in such cases, the Council can simply advise
the Department of an expected underspend and request that the funds be diverted
elsewhere. In other words, under the new system the Department will have to approve
the diversion of capital funds to lower priority areas. Under the current allocation
system, the Department is not aware if such diversions of targeted funding is taking
place e.g. from high priority to low priority Scheme Takeovers.
It could be argued that the Rural Water Programme is a devolved local authority programme
and such changes to the capital allocations system would be quasi- recentralisation of the
Programme. It must be remembered, however, that the Programme was devolved to local
authorities in 1997, when Councils could only approve individual public schemes costing less
than £250,000. The situation has changed radically since then particularly following the
European Court of Justice ruling against Ireland. Expenditure under the Group Scheme
elements of the Rural Water Programme has increased by 105% between 2003 and 2006 from
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€48.542 million to €99.847 million per annum. This funding has come substantially from
central Government. Implementation of the Action Plan for Rural Water Quality has only
been very modest for some measures i.e. takeovers and connections to the public mains.
Therefore, it is essential that the Department has an allocation system in place to ensure that
funds are targeted in priority areas and a coherent reporting system to monitor progress in
achieving required outputs and outcomes.
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Chapter 7
Conclusions and Recommendations
192
Introduction
As has been seen from this Review, the implementation of the Rural Water Programme is an
extremely complex and diverse undertaking. Unlike the Public Water Services Investment
Programme, its implementation is dependent on the co-operation of the privately owned and
voluntarily run Group Schemes’ sector. Also because it is a devolved local authority
programme, the Department is dependent on the initiative of individual local authorities in
delivering its objectives. It is also unique in that there is very little discretion available to the
Department in funding this capital programme as Ireland is facing the imminent prospect of
having to pay millions of euros in fines to the European Commission if it fails to bring Group
Water Schemes into compliance with the European Union’s Drinking Water Directive.
Finally, there is no neat ‘one size fits all’ solution as the Rural Water Programme involves
providing costly water treatment, using five different upgrade solutions, to dispersed
communities in remote areas. Therefore, the issue of delivering value for money is a
challenging but vital necessity.
Limitations of Study
Before discussing the Conclusions and Recommendations of this Review, it is important to
first qualify them by setting out the limitations of this study.
Implementation analysis
The last substantive information collected to date on implementation to date under the Rural
Water Programme was for the June 2006 Report to the European Commission (see table
below). Therefore, the implementation data used in this 2003-’06 Review does not reflect
scheme implementation during the second half of 2006. The only exception was the DBO
bundles programme, where more up to date implementation information was made available
by DBO Client Representatives.
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Implementation Status of Group Water Schemes by upgrade solution category – June 2006
Treatment Solutions
% Solution In
Work in Upgrades Total
% Upgrades
breakdown Planning Progress Complete Schemes complete
DBO
Non-DBO
Connect to Public Main
Council Takeover
Disinfection/Sterilisation
Public Source
35%
3%
16%
9%
17%
20%
100%
Total No. of Schemes
% implementation
19
7
85
35
19
21
209
9
27
27
11
15
30
5
6
3
92
109
258
21
118
65
122
145
186
26%
298
41%
245
34%
729
12%
24%
5%
5%
75%
75%
Ref. Figures derived from June 2006 Report to the European Commission on Measures to bring Group
Water Schemes into compliance with the Drinking Water Directive
A revised implementation report was sent to the European Commission in May 2007, which
provided details on schemes’ implementation as of 30th April 2007 (see table below). This
information was only made available after the completion of this 2003-’06 review but it
shows an improved situation in relation to implementation of the two water quality upgrade
solutions involving connection to the public mains. The difference in the total number of
schemes designated under each of the treatment solution types is explained by the fact that the
planned solution for some schemes has changed since June 2006. Also as explained in this
Review, the June 2006 Report had understated the number of completed Schemes connected
to the public mains by categorising them as public source so this has been corrected.
Implementation Status of Group Water Schemes by upgrade solution category – 30th April 2007
Treatment Solutions
DBO
Non-DBO
Connect to the Public Main
LA Takeover
Disinfection/Sterilisation
Public Source
Total No. of Schemes
% status
In
In Advanced Work in
Planning Planning
Progress
Upgrades Total
% Upgrades
Complete Schemes Complete
3
5
31
25
20
2
88
1
6
19
5
2
34
8
13
27
4
2
102
21
46
34
139
91
227
35
96
105
168
97
45%
60%
48%
32%
83%
94%
86
12%
121
16%
88
12%
433
60%
728
59%
Ref. Figures derived from background data collected for May 2007 Report to the European Commission
on Measures to bring Group Water Schemes into compliance with the Drinking Water Directive
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Effectiveness analysis
The most up to date EPA water quality test results available were for 2005. Therefore, this
Review was dependant on local authorities for confirmation of whether or not Group
Schemes, upgraded after 2005, were compliant. However, given that the EPA’s published
data is based on local authority test results, there is no reason to assume that the local
authority data is not accurate.
Efficiency analysis
Data on the capital cost of completed DBO Schemes is incomplete as these Schemes are only
recently finished and no final accounts are available for any of the DBO schemes. Provisional
DBO Client Representative data was used in this Review. It is likely, therefore, that the DBO
capital costs may be understated. DBO pipe network upgrade data is not available yet. This
means that unit cost i.e. cost per house comparisons between DBO projects and with other
treatment solutions is very provisional. In any case, previous studies have shown that unit cost
comparisons of the water sector only provide limited indicators of relative value for money,
due to the unique nature of individual water projects, particularly when serving dispersed
rural communities. Fitzpatrick Associates have also predicted that it will not be possible to
conclusively assess the value for money of DBO projects for many years (2005, p.96).
Councils stated in most cases that all alternative water quality upgrade options were costed to
ensure that the ‘most economically advantageous” option was chosen. However, documentary
verification of this was not provided in most cases. It will be recommended that this
verification be included in the DBO final accounts in the interests of transparency. It was
only possible to carry out a limited assessment of the relative operational and maintenance
(O&M) costs of the DBO and the two public source solutions involving connection to the
public mains. This was because DBO O&M data is very provisional and also because the
basis for calculating local authority water charges differs from Council to Council. It was not
possible to carry out an O&M comparison with the Disinfection/Sterilisation and Non-DBO
solutions as they are voluntarily maintained so there is no comparative cost data available.
Potential Areas for further Study
The comparison of provisional DBO treatment plant O&M costs and local authority O&M
charges (see p.123.) would appear to suggest that the volumetric i.e. variable costs of DBO
195
plants are considerably lower. This could be explained by the inclusion of network
maintenance overheads in the local authority water charges unlike the DBO contractors’
charges. This apparent cost differential needs to be explored further based on more definitive
DBO O&M data and more information on the basis used for calculating individual local
authority water charges for non-domestic consumers. As already stated (see p.69.), the
Department may wish to look at standardising the basis for calculating local authority water
charges in a further study.
Conclusions of the Rural Water Programme Review
Validity of Programme Objectives
The primary objective of the Rural Water Programme during the period of the Action Plan for
Rural Drinking Water Quality 2003-2006 was to bring the quality of rural water supplies, and
specifically privately sourced Group Schemes, into compliance with the Drinking Water
Regulations 2000. This is clearly stated in the Department of the Environment, Heritage and
Local Government’s Statement of Strategy. The June 2006 Report to the European
Commission and the 2007 EPA Drinking Water Quality Report clearly indicates that, in spite
of significant implementation activity, this objective has not yet been fully achieved.
Therefore, the primary objectives of the Rural Water Programme continue to be relevant post
2006.
Implementation of Water Quality Upgrade Solutions
As has been seen, the best progress to date on water quality upgrade implementation has been
with DBO and Disinfection/Sterilisation Schemes. Much of the work on Disinfection
/Sterilisation Schemes was, however, carried out prior to the 2003-’06 period under review so
minimal upgrades were needed. Progress on completing DBO treatment plant bundles has
also been substantial in spite of the complicated nature of such contracts. Implementation of
the two public water connection solutions has been relatively slow and, according to local
authority questionnaire returns, the unwillingness of some non-domestic Group Scheme
consumers to pay for local authority water appears to lie at the heart of this delay in many
cases.
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Effectiveness of Water Quality Upgrade Solutions
The Environmental Protection Agency (EPA) regard the quality of public water supplies as
generally satisfactory unlike many Group Schemes’ private water supplies (2007). Therefore,
the Takeover solution would appear to be the most effective as Group Schemes are fully
absorbed into the public water system and their pipe networks are maintained by professional
local authority personnel. Similarly, the Connection to Public Mains (CTPM) solution is
effective but there is an effectiveness risk factor involved as Group Schemes maintain
responsibility for pipe network maintenance. The DBO treatment plant solution also appears
to be effective but has the same pipe network maintenance risk factor.
Disinfection/Sterilisation and Non-DBO schemes also have this risk factor as well as a more
serious risk of non-compliance if Group Schemes do not properly operate and maintain their
treatment infrastructure and protect their water source. EPA test result data for several Group
Schemes upgraded using the Disinfection/Sterilisation and Non-DBO solutions still show
exceedances of microbiological and chemical parameters in some counties. It is probable, in
many cases, that this may be due to inadequate operation and maintenance of treatment
facilities and pipe networks by Group Scheme volunteers. Therefore, there is a question mark
over the effectiveness of those latter two solutions without active Group Scheme maintenance.
The EPA also raised concerns, in its 2007 Drinking Water Quality Report, in relation to the
level of water quality monitoring and testing carried out by local authorities on Group
Schemes in 2005. Water quality monitoring is key to identifying Group Scheme in need of
possible upgrades and also to assess the effectiveness of these water quality upgrades. The
Minister for the Environment, Heritage and Local Government has given the EPA additional
powers to take enforcement action against local authorities, who do not fulfil their statutory
monitoring requirements, under the new 2007 Drinking Water Regulations.
Efficiency of Water Quality Upgrade Solutions
The relative efficiency of each of these individual solutions is more difficult to measure as
they are very varied in nature and as such reliable and meaningful comparisons are harder to
make. However, as grants are made on a cost per house basis, the relative cost of a number of
schemes from each upgrade solution, were compared (see p.142). There were wide variations
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in the cost per house of Schemes upgraded under the same solution never mind different
solutions. In many respects, the exercise bore out the conclusions of the previous two recent
reviews of the Water Sector discussed in the Literature Review i.e. 2002 Departmental
Expenditure Review and the 2006 Fitzpatrick Associates NDP Review. It is actually very
difficult to make meaningful cost comparisons, as individual water projects are by their nature
unique.
That said, certain patterns can be discerned. Generally, the Disinfection/Sterilisation solution
is way and by far the cheapest solution in cost per house terms and the DBO treatment plant
solution is the most expensive. Some of the DBO plants appear to have lower cost per houses
than others, which could be as a result of the economies of scale of the size of the schemes or
the size of the overall DBO Bundle. The practice of procuring DBO treatment plants in
bundles to create critical mass rather than individually appears to have been successful in
attracting more competitively priced bids. That said, it must be remembered that the DBO
figures are provisional due to the current lack of final accounts as these Schemes are only just
completed. Therefore, it is likely that the cost per house for DBO Schemes are actually
understated as there are outstanding Design Build costs yet to be included.
Provisional Operational and Maintenance (O&M) data for DBO treatment plants would
suggest that the variable O&M costs of DBO plants are lower than the local authority variable
charges for non-domestic Group Scheme consumers connected to the public mains. More
definitive data and further study is necessary to confirm this. However, there is anecdotal
evidence to suggest that an awareness of the relatively higher cost of local authority water
charges is motivating non-domestic Group Scheme members to favour the DBO treatment
solution over connection to the public mains or Council takeover. By contrast, many domestic
Group Scheme consumers would probably be better off being connected to the public mains,
where this is a viable option, as they would receive up to 50,000 gallons of water per house
free each year and would not have to pay DBO O&M costs.
Discussion of Water Quality Upgrade Conclusions
As can be seen from the above analysis, Disinfection/Sterilisation is generally the cheapest
water quality upgrade solution with DBO treatment plants the most expensive. However,
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Disinfection/Sterilisation is limited as an option to a relatively small number of County
Councils areas where the water chemistry, mainly groundwater, is naturally of a high
standard. Even with that, there are issues with the sustainability of this minimal treatment
solution due to inadequate source protection and poor management of treatment infrastructure
and pipe networks by some Group Schemes. Local authorities should insist that members of
such Group Schemes participate in training programmes provided by the Water Services
National Training Group (WSNTG) or otherwise face prosecution under the Drinking Water
Regulations. It should be noted that the Disinfection/Sterilisation treatment solution appears
to be working quite well in some areas due to the diligence of Group Schemes in maintaining
their water treatment infrastructure. In some other cases, it is only an interim treatment
solution and it is intended that it will be superceded by a more robust treatment solution in the
future.
A more consistently effective and relatively cost efficient solution is connection to the public
mains or complete takeover of Group Schemes, which are within a reasonable distance of
existing public mains. However, as already discussed, some Group Schemes have delayed
solution implementation or opted for standalone DBO treatment plants rather than connection
to the public mains due to local authority charges for non-domestic water charges. Local
authorities must continue to stand firm on this issue particularly where connection to the
public mains is the far cheaper option on value for money grounds. Also, it is important to
ensure that the interests of domestic consumers on Group Schemes are protected as, in many
cases, they are financially better off being connected to the public mains, where this is
possible.
Finally, while DBO treatment plants are relatively expensive on a cost per house basis, they
are often the only viable treatment solution for Group Schemes, which are remote from the
public mains, and where the raw water quality is inadequate for minimal
disinfection/sterilisation treatment. It is clear that achieving value for money was a strong
factor in developing DBO projects. Evidence of this is shown by initiatives such as:

Bundling of DBO projects to attract innovative and competitive bids from the national
and international water infrastructure construction market
199

Merging/Sub-bundling of schemes to reduce the number of treatment plants required

Change from Pre-tender to post-tender planning to encourage more cost effective
designs

Transference of construction risk to DBO contractor by limiting capital cost increases

Economic plant design capacities with water conservation measures to reduce leakage
and over abstraction of water for treatment purposes
It is essential that the Department and Councils continue to try and deliver these projects on as
economical a basis as possible through measures such as DBO procurement bundling and
sub-bundling, to avail of treatment technologies at the most competitive market prices, and
also through economical plant designs with minimal UFW allowances.
Non-Water Quality Upgrade Measures
Network Upgrades
Expenditure on pipe network upgrades of €105 million was the second highest spending
capital measure during 2003-’06 after DBO projects. It has been shown from various leakage
studies that leakage control measures, including universal metering and the replacement of
critical network mains, to reduce unaccounted for water (UFW) is more efficient than
building additional plant treatment capacity. Network upgrade expenditure is also needed to
sustain treatment solution effectiveness by avoiding the recontamination of treated water in
sub-standard Group Scheme pipe networks. The National Federation of Group Water
Schemes (NFGWS) predicts that “replacement of sub-standard networks will be the next
major infrastructural challenge facing the rural water sector” (Appendix 3). It should be noted,
however, that in many of the cases examined in this study, the network upgrade cost exceeded
the actual treatment solution cost, with complete network replacement in some cases. It is
important, therefore, that expenditure on network upgrades and critical mains replacements is
carefully targeted based on sound engineering assessments of the location of leaks and the
future hydraulic needs of the pipe network.
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Annual Domestic Subsidy
This is a relatively small element of the Rural Water Programme but an ongoing current
expenditure commitment. There has been a 50% increase in annual expenditure from €5.3
million to €7.9 million between 2003-2006. This rate of annual expenditure is likely to
increase in the short term as many Group Schemes begin to claim the higher €196.81 per
house rate for the operation and maintenance of their new DBO treatment plants.
The National Federation of Group Water Schemes have made proposals for increases in the
domestic water subsidy rates to reflect the current operational and maintenance (O&M) costs
for Group Schemes. However, any decision to increase domestic subsidy rates must be based
on a rigorous study of metered water usage data to ensure that there is no cross subsidisation
of non-domestic water consumers or subsidisation of UFW leakage levels in excess of the
25% limit. Also, Councils must continue to ensure that Group Schemes observe the
conditions of the Subsidy scheme. The Department may also need to consider making active
source protection measures by Group Schemes a condition for payment of the subsidy. The
State’s annual domestic subsidy payment, to households connected to Group Schemes, is
likely to remain in place for the foreseeable future, on the grounds that it provides some level
of equity with domestic water consumers on the public water system.
New Schemes and Scheme extensions
This is a very significant measure as new Group Schemes could potentially add to the number
of sub-standard schemes requiring water quality upgrades in the future, if not controlled.
Analysis of New Schemes measure indicates that 72% of the 610 new schemes constructed
during the 2003-’06 period, were built with a connection to the public water supply. The
number of new Group Schemes built with private water sources declined each year. This is a
very encouraging sign as the EPA has identified Group Schemes with private sources as being
the main risk factor for water quality problems. If any new or extended scheme grows to
beyond 15 houses or connects in to a premises with a public or commercial function e.g. dairy
farm, then the water quality must comply with the parameters of the Drinking Water
Regulations and water treatment upgrades may be required.
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Potential Future Funding Commitments
It is clear from the June 2006 Report to the European Commission that there is still
considerable work to be done, which will require capital funding. Although, the bigger
schemes have been identified, the number of smaller Group schemes serving a commercial or
public function has yet to be finalised. Councils were asked to identify such schemes as part
of the data collection for the June 2006 Report to the European Commission. Some schemes
were identified but it is believed that a significant number of others exist.
One of the difficulties is that commercial or public function is not specifically defined under
the Drinking Water Directive or Regulations. The EPA did, however, issue a guidance
circular (DW 01/06) in relation to this on 11th May 2006 and included dairy farming and food
production as commercial functions. Given that Group Schemes are located in rural
agricultural areas, it is fair to assume that there are a considerable number of small Group
Schemes with connections to a dairy farm. It is imperative, therefore, that local authorities
identify such Group Schemes in their area so that upgrading solutions can be determined and
put in place. The EPA have been granted additional enforcement powers under the 2007
Drinking Water Regulations to ensure that local authorities identify and adequately monitor
the water quality of Group Water Schemes required to comply with the Regulations.
For all upgrade solutions, except local authority takeover, Group Schemes continue to be
responsible for the maintenance of their pipe networks. Local authorities and DBO Client
Representatives have both identified poor network maintenance and re-contamination of
treated water in Group Scheme networks as possible risk factors. This is exacerbated by the
fact that volunteerism in the Group Scheme sector is gradually declining and the National
Federation of Group Water Schemes has identified the future need for professional managers
for some Group Schemes. The alternative is that more and more Group Schemes will have to
be taken into public charge at even greater cost to the taxpayer. As already stated, the
NFGWS also predicts that future investment will be required to replace sub-standard pipe
networks. It is likely, therefore, that even after the present programme of water quality
upgrades is complete, there are likely to be continuing financial demands from the Group
Water Schemes sector.
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Alternative Organisational Approaches
The options essentially are that the programme should continue to be run by local authorities
or alternatively be transferred back to Departmental control. Given the current urgency to
upgrade Group Schemes, it is questionable whether there would be any added value in recentralising the administration of the programme. In fact, any radical administrative changes
during this critical period would be likely to disrupt rather than improve programme
implementation. It was concluded that the diversity and community nature of the Group
Schemes Programme means that it is best administered on a local authority basis by a cohort
of dedicated Rural Water Liaison officers and should remain so. There is, however, an
inconsistency in implementation under the various water quality upgrade solutions and lack of
routine data reporting to the Department on programme outputs. Revised data reporting
requirements for Councils are proposed in Chapter 6 on Physical Indicators.
Possible implications of ECJ fines
Given the potential threat of European Court of Justice (ECJ) fines if Ireland does not comply
with the Drinking Water Directive in relation to Group Schemes, it is essential that the water
quality upgrade programme is completed without delay. Local authorities have been given a
broad range of powers under the Drinking Water Regulations 2007 to take action against nonco-operating Group Schemes and to carry out remedial works themselves if necessary. Given
that the implementation of the Rural Water Programme is devolved to individual local
authorities, it does not seem equitable to expect national taxpayers to have to carry the whole
burden in the event of ECJ fines being imposed due to a local infringement. This would be
particularly the case if fines were imposed due to the inertia of a small number of Councils in
enforcing their powers under the Drinking Water Regulations against non-cooperative Group
Schemes in their administrative area. It could be more equitable to develop a mechanism
whereby such Councils carry the cost of potential fines through their annual Local
Government Fund allocation. The Department has already warned of the possibility of such
sanctions against local authorities in public fora (Athlone Seminar for Rural Water Liaison
Officers-June 2006).
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Alternative Policy Approaches - Source Protection
Article 7.3 of the EU’s Water Framework Directive states that “Member State shall ensure the
necessary protection for the bodies of water identified with the aim of avoiding deterioration
in their quality in order to reduce the level of purification treatment required in the production
of drinking water”. This would appear to indicate that in the future ‘end of pipe’ treatment of
polluted water may no longer be regarded as sufficient and that member states will be legally
required to ensure that their water sources do not become contaminated in the first place.
Therefore, the issue of source protection of drinking water supplies is likely to come to the
fore in the future. The National Federation of Group Water Schemes also agrees that ‘end of
pipe’ solutions are not sustainable into the future.
The Department is currently working on a Master Plan to meet the requirements of the Water
Framework Directive and specifically to produce River Basin Management Plans (RBMP) by
2009. It is also currently engaged with the Department of Agriculture and Food in the
implementation of a National Nutrient Management Plan, in order to comply with the 1991
Nitrates Directive, to reduce the impacts of the land spreading of fertilisers and other nutrients
on water sources. The Department has issued guidance to local authorities on groundwater
protection (SP05/03) and is currently funding a National Pilot Source Protection Study of
Churchill Oram Group Water Scheme in County Monaghan. This will also include an
extensive survey of the condition of septic tanks and their potential impacts on water quality.
The Water Services Act 2007 gives additional enforcement powers to local authorities to
require householders to properly maintain septic tanks. Active local source protection
measures by Group Schemes may also need to be added as a condition for receipt of the
annual domestic subsidy payment.
Performance Indicators
The Review of the Rural Water Programme has found that there is a mismatch between inputs
and outputs measurement categories for reporting purposes (see Chapter 6). Inputs and
outputs reporting relating to differing objectives are also mixed in together. There is also a
need for more output data in relation to capital spending measures, unrelated to compliance
with the Drinking Water Regulations. There is also a need for earlier water quality
exceedances information from local authorities in relation to Group Schemes, which are
204
required to comply with the Drinking Water Regulations. Data needs to be periodically
collected on new Group Schemes requiring compliance with the Drinking Water Regulations,
due to an expansion in the Schemes’ size or connection to premises, with a public or
commercial function. Finally given the level of expenditure on pipe network upgrades, the
Department and local authorities should set specific UFW reduction targets as the outcome for
such investment.
Recommendations of the Rural Water Programme Review
General Recommendations
1. The Programme of water quality upgrades required to comply with the Drinking
Water Regulations must be completed without delay to protect the public health of
Group Water Scheme householders.
2. It is important that the Department reminds Councils that while a partnership approach
with the Group Schemes’ sector is vital for programme implementation, the ‘most
economically advantageous’ effective treatment approach must ultimately continue to
be adopted in the interests of the taxpayer. Local Authority Final Accounts for all
water quality upgrade projects should verify that all alternative water treatment
options were considered and costed. Final Account verification should also be
provided that Group Scheme capital contributions have been fully paid and that the
Department’s €6,476 per house grant limit has not been exceeded.
DBO treatment solution (p.86.)
3. While the local authority questionnaire returns suggests that in most cases, the DBO
option was the most cost efficient solution adopted for that situation, there is a need
for greater transparency in relation to this. It is recommended that for all future DBO
project proposals, a report should be prepared costing all alternative options to the
DBO route and comparing those costs to the DBO cost.
4. County Councils have stated that in most cases all alternative options to DBO were
costed but verification of this was not provided, in most cases, within the time limits
205
of this Review. This verification should be included in the local authority Final
Accounts of all DBO Bundles completed to date as well as confirmation of the final
cost of the civil works contract and the payment by each Group Scheme of their 15%
capital contribution. This is important for transparency and will also be of assistance
to the Office of the Comptroller and Auditor General in any future audit of DBO
Bundle expenditure.
5. In future cases where Group Schemes cannot be connected to existing public supplies
due to insufficient existing plant capacity, the cost of increasing existing public water
treatment plant capacity must be considered as an option by local authorities.
6. Local authorities should continue to assess opportunities for achieving greater value
for money, when planning future DBO Bundles, by rationalising the number of water
treatment plants in DBO Bundles so that two or more Group Schemes can be served
by the same treatment plants.
Non-DBO solution (p.108)
7. The effectiveness of this solution is questionable possibly due to inadequate operation
and maintenance of the treatment solution by some Group Scheme volunteers. Local
authorities should insist that members of these Group Schemes participate in training
programmes provided by the Water Services National Training Group (WSNTG) in
such cases or otherwise face prosecution under the Drinking Water Regulations. In
cases where inadequate maintenance is not the problem, Councils should review the
effectiveness of this solution for such Group Schemes.
Public Source Solutions (p.113.)
8. Implementation is the main problem for public source solutions mainly due to
resistance to local authority water charges for non-domestic Group Scheme
consumers. Local authorities must, where necessary, utilise the new powers available
to them under the 2007 Drinking Water Regulations to take enforcement action
against non-co-operating Group Schemes, including the direct implementation of
remedial works.
206
Disinfection/Sterilisation Solution (p.129.)
9. The effectiveness issues in relation to the Disinfection/Sterilisation solution are a
matter for concern given that it is the water quality upgrade solution selected for 122
Group Schemes (17% of the total). Local authorities should insist that members of
non-compliant Group Schemes, using this treatment solution, participate in training
programmes provided by the Water Services National Training Group (WSNTG) or
otherwise face prosecution under the Drinking Water Regulations. In cases where
disinfection/sterilisation is only an interim treatment solution, local authorities should
put permanent solutions in place as soon as possible.
10. While there were no exceedances of Trihalomethanes (THMs) identified for any of the
four Counties studied, the proportion of schemes tested for THMs in each County was
quite small. It might be prudent if local authorities increased the level of testing for
THMs for Disinfection/ Sterilisation schemes, given the possible carcinogenic risk
factors.
11. Where vulnerable water sources are identified as a risk factor for the sustainability
Disinfection/Sterilisation treatment solution, local authorities should require the
relevant Group Schemes to implement more robust local source protection measures.
Network Upgrades (p.143.)
12. Given that network upgrade costs frequently exceed water treatment costs and that the
NFGWS have predicted that demand for network upgrades will increase, it would be
timely to issue updated guidance to Councils in relation to approving pipe network
upgrades. Such upgrades should only take place based on the results of a methodical
leakage control study to ensure that upgrade funds are targeted at replacing critical
mains. In addition, where substantial network upgrades are being proposed, a
hydraulic study should be carried out to ensure that the proposed upgrades will meet
the future requirements for 2025 demand+25% UFW.
207
13. It is vital that the Department considers funding universal metering of all Group Water
Schemes being upgraded under the Rural Water Programme, as there is no incentive to
conserve water or minimise waste without it. Such grant aid is currently only available
to DBO Schemes under the network upgrades measure and consideration should be
given to extending this to all upgraded Group Schemes. Quite apart from being a
charging tool, meters are more importantly a vital management tool for operating
water distribution systems and identifying the precise location of water leakages. It
will also create greater transparency in relation to the sources of water usage and
leakage in Group Schemes, particularly between domestic and non-domestic users. In
this way, it reduces the risk of cross-subsidisation of the non-domestic users by
domestic users and the subsidisation of excessive UFW, through the domestic
household subsidy. Additional metering could be funded through savings created by a
more targeted approach to network upgrades, based on leakage control studies. The
National Federation of Group Water Schemes (NFGWS) have expressed support for
the concept of universal metering of Group Scheme connections (See Appendix 3).
Domestic Household Subsidy (p.152.)
14. Any decision to increase domestic household subsidy rates must be based on a
rigorous study of metered water usage data to ensure that there is no crosssubsidisation of the non-domestic sector by the domestic sector, at the tax payers’
expense. Also, an increased domestic subsidy cannot be used to subsidise UFW
leakage levels on Group Schemes in excess of the 25% limit.
15. Local authorities must ensure that the achievement of policy objectives such as water
conservation, water quality and transparency for Group Water Scheme members, as
already required under the existing subsidy scheme, are being implemented by Group
Schemes.
16. There is also a need to link the payment of subsidies to the active implementation of
source protection measures by Group Schemes to protect their drinking water sources
from contamination.
208
New Group Schemes (p.159.)
17. All new Group Schemes approved must be connected to the public mains or an
existing DBO treatment plant, where it is technically and economically viable to do so
under existing grant limits.
18. New Group Schemes with private sources should only be licensed where there is no
other viable drinking water solution for existing houses.
19. New Group Schemes with private sources should not be licensed unless a
comprehensive risk assessment of alternative water sources has been carried out, and
the optimum water source has been selected.
20. Active local source protection measures should be put in place for new Schemes,
which can be verified by Councils on an audit basis, as a condition for continued
subsidy or capital funding.
21. New Group Schemes should only be licensed in areas where it is verified that they are
compliant with local authorities’ County Development and Local Area Plans for
housing development.
Potential future funding issues/ECJ fines (p.163.)
22. Local authorities should ensure that all small Group Schemes in their area, connected
to commercial or public premises, are identified so that water quality upgrading
solutions, if necessary, can be put in place for these Schemes, to comply with the
Drinking Water Regulations. The Minister for the Environment, Heritage and Local
Government has given the Environmental Protection Agency (EPA) additional
enforcement powers under the 2007 Drinking Water Regulations to ensure that local
authorities fulfill their statutory monitoring obligations in this regard.
23. Local authorities and DBO Client Representatives have both identified poor network
maintenance and re-contamination of treated water in Group Scheme networks as risk
factors. Local authorities should require members of non-compliant Group Schemes to
209
participate in training programmes provided by the Water Services National Training
Group (WSNTG) or otherwise face prosecution under the Drinking Water
Regulations. In the longer term, the Department, in conjunction with local authorities
and the NFGWS, may need to consider alternative professional based approaches to
Group Scheme maintenance due to declining volunteerism in the Group Schemes
sector.
24. Given that the implementation of the Rural Water Programme is devolved to
individual local authorities, it does not seem equitable to expect national taxpayers to
have to carry the whole burden in the event of ECJ fines being imposed due to a local
infringement. This would be particularly the case if fines were imposed due to the
inertia of a small number of Councils in enforcing their powers under the Drinking
Water Regulations against non-cooperative Group Schemes in their administrative
area. It could be more equitable to develop a mechanism whereby such Councils carry
the cost of potential fines through their annual Local Government Fund allocation.
Alternative Policy Approaches – Source Protection (p.170.)
25. Given the implications of the Water Framework Directive and the costs of compliance
with the Drinking Water Directive, the Department may need to consider introducing
more robust measures in the future in order to protect drinking water sources from
contamination. Local authorities should first implement the existing powers available
to them. Active source protection by all Group Schemes should be added as a
condition for receipt of the annual domestic subsidy payment.
Performance Indicators (p.175.)
26. The Performance Indicators proposed in Chapter 6 should be used to better monitor
the performance of the Rural Water Programme. Given the level of expenditure on
pipe network upgrades under the Rural Water Programme, the Department and local
authorities should set specific UFW reduction targets as the outcome for such
investment.
210
Conclusions
For the future then, there will have to be a number of priorities. Public health has to be the
first and foremost objective. Therefore, implementation of all remaining water quality
upgrades must proceed without further delay in order to comply with the Drinking Water
Regulations. Secondly, the water quality upgrade solution selected for each Group Water
Scheme must be both effective in ensuring compliance with the Drinking Water Regulations
and also must be the most cost efficient workable solution, from the perspective of the
taxpayer. Therefore, Group Schemes should be connected to the public mains, where this is
the more economically viable option. Also where a DBO treatment plant is the only viable
option, the number of treatment plants in a DBO bundle should be rationalised to serve two or
more Schemes, where this is technically possible and economically viable, in order to keep
the number of treatment plant constructed to a minimum. The levels of capital grant aid being
paid to the Group Schemes’ sector is relatively generous by European standards (see Scottish
example in the Literature Review) so it is only fair that the Irish taxpayer receives value for
money from this investment. Ongoing investment in leakage control, targeted network
upgrades and metering is also vital to reducing UFW and operating Group Schemes in a more
cost efficient manner. There also needs to be a greater emphasis on source protection
measures rather than just ‘end of pipe’ treatment solutions.
Much has been achieved from the Department’s relationship of co-operation and consultation
with the Group Schemes’ sector through the National Rural Water Monitoring Committee
(NRWMC). The National Federation of Group Water Schemes (NFGWS) was founded in
1997 to try and achieve parity of treatment for rural communities from the State (Rural Water
News-Spring 2007). The domestic household operational subsidy was introduced as a way of
creating greater equity for domestic householders connected to Group Schemes, by
comparison to their counterparts on the public water supply. The Department and local
authorities must continue to work with the Group Schemes’ sector in the same spirit of cooperation dealing with the interests of both domestic and non-domestic Group Scheme
consumers in an even handed manner. Local authorities must ensure that the interests of
domestic consumers are protected in decisions in relation to Group Scheme solutions and also
that non-domestic consumers are treated in an equitable manner to their counterparts on the
public mains.
211
The Department and local authorities have demonstrated a large degree of innovation in trying
to achieve value for money in the delivery of water quality upgrading solutions to the Group
Schemes’ sector. This is particularly noticeable in the case of DBOs. 10% of the Irish
population are served by Group Water Schemes and, unlike the public water sector, its
domestic consumers have to directly contribute towards the operational costs of providing
treated water to that sector. Many of these voluntarily run Group Water Schemes have shown
great innovation in reducing their operational and maintenance (O&M) costs through water
conservation and leakage control measures. There is recognition in many Group Scheme
households that water is a valuable environmental resource, which should not be wasted and
such initiatives provide an example to producers and consumers of drinking water in the
public water sector.
212
Appendices
213
Appendix 1
Breakdown of relevant Group Water Schemes by County
Source: Report to the European Commission on Measures to bring Group Water Schemes into
compliance with the Drinking Water Directive – June 2006 p. 8.
Note: Explanation of terms in above table

Schemes – No. of Group Water Schemes

Domestic – No. of domestic connections i.e. households

Annex 14 Schemes – Group Schemes serving > 50 persons cited in 2002 ECJ ruling

Non-Annex 14 Schemes - Schemes serving > 50 persons not cited in 2002 ECJ ruling
but subsequently identified by local authorities as requiring compliance
214
Appendix 2
Membership of National Rural Water Monitoring Committee
Chairman: Dr. Tom Collins, NUI Maynooth
Secretary: Mr. Carthage Cusack, Department of the Environment, Heritage and Local
Government
Member Organisations
County and City Managers’ Association
Irish Countrywomen’s Association
Irish Creamery Milk Suppliers Association
Irish Farmers’ Association
National Federation of Group Water Schemes
General Council of County Councils
Local Authority Members Association
Department of Community, Rural and Gaeltacht Affairs
Department of the Environment, Heritage and Local Governme
215
Appendix 3
National Federation of Group Water Schemes (NFGWS) response to questions re.
Rural Water Programme Value for Money (VFM) issues
1. What, in your view, would be the outcome if the State simply required the GWS by
law to meet the criteria of the Drinking Water Directive, without providing capital
funding, and passed on any fines for non-compliance to individual GWS?
When originally established, group water schemes were driven primarily by the requirements
of farming. Drinking water quality was not an issue, particularly as many households retained
individual wells for their potable supply. The transition of schemes to providing drinking
water as their primary focus only commenced following the establishment of the National
Federation of Group Water Schemes and the introduction of State investment under the Rural
Water Programme in 1998. Without capital grant aid, the sector simply could not meet the
obligations of the Drinking Water Directive. With few exceptions, schemes that are noncompliant at present would remain so, as they would not be able to raise the resources to
remedy the situation, while at the same time meeting the costs of other capital works and
general maintenance and administration. This would inevitably result in committees of
management simply ‘walking away’ (rather than being held legally accountable) and schemes
collapsing. In such a scenario, local authorities would have no option but to move in to
upgrade and administer them. This would require substantially greater State resources than the
current investment programme which benefits from the voluntary input of local GWS activists
and a 15% local contribution towards capital works (apart from the cost of water treatment).
2. What, in your view, would be the outcome if the State withdrew current funding i.e.
the subsidy for GWS?
Apart altogether from the iniquitous situation that would arise vis-à-vis the water entitlements
of consumers on public schemes (that are wholly subsidised) the NFGWS feels very strongly
that the part-funding, through subsidy, of the management and operation of a group scheme is
an absolute prerequisite to the modernisation and continued sustainability of the GWS sector,
not least in ensuring compliance with the Drinking Water Directive. While the NFGWS
(through our Management Training Course and quarterly magazine) is actively encouraging
schemes to move towards pricing structures that will lead to increased self-sufficiency in the
long-term, there is still some distance to go before this is achieved. In the short to medium
term, therefore, the operational subsidy will remain essential, while a subsidy in respect of the
fixed element of water treatment will be required for the O&M contract period.
3. Is the current subsidy level adequate? What safeguards are in place to ensure
transparency so that domestic consumers are not subsidising non-domestic water usage
in Group Schemes?
It is totally inadequate at present. The last review of subsidy levels was in March 2000.
Subsidy levels, at present, do not reflect the growing financial demands on schemes in the
new and ever-changing legislative and regulatory environment that exists for water supply
services. As with other organisations, we are finding that the purely voluntary effort of a few
216
dedicated individuals (and they are getting fewer!) is not equal to the demands of a modern
water service. As a result (and to ensure schemes maintain quality in all aspects of their
business) the NFGWS is promoting the employment of paid management/maintenance
personnel on group schemes and a move towards greater professionalism in all areas of the
administration. Apart from the rising costs of administration, some schemes face very high
DBO fixed costs (for treated water), yet these costs have to be met for the next 20 years. Even
with appropriate charges on metered usage, this creates a huge and ongoing financial burden
on schemes and leaves them with very few resources to invest in wider scheme
management/administration. As for safeguarding domestic consumers, universal metering is
being introduced both as a water management tool and as the basis for an equitable charging
system that fully reflects the principle of ‘polluter pays’. Charging on metered usage protects
domestic consumers from cross-subsidising the business or farming sectors.
4. Is the annual Dept grant to the NFGWS necessary for funding its operations?
Yes, it is! The partnership arrangement introduced under the Rural Water Programme
established the active participation of three stakeholders; the Department, local authorities and
the NFGWS. It was agreed that the latter two (local authorities and the NFGWS) would
require State funding to perform their respective roles. While the federation is very grateful
and fully acknowledges the assistance we receive from the State, we sincerely believe that
VFM is being achieved. Further, we firmly believe that the range of activities undertaken by
the federation in advancing the Rural Water Programme would not be possible without
continued funding. In brief, this funding has supported the reinvigoration of the entire rural
water sector through the direct guidance, encouragement and training programme of the
NFGWS. We would argue that the supports currently available should be increased and
index-linked to inflation to reflect the ever-expanding workload of the Federation in preparing
schemes to meet the new environment for drinking water services. For details of the wide
range of those services and the active delivery by Federation staff, we would refer you to our
Annual Reports, Strategic Plan and quarterly magazine, all of which are available on our
website at www.nfgws.ie.
5. What level of contributions are householders typically making from their own
resources towards O&M costs?
Because subsidy hasn’t been reviewed since 2000 and, therefore, doesn’t reflect the full costs
of providing a drinking water service, schemes are forced to charge households for a
proportion of O&M costs. It is difficult to provide a ‘typical’ contribution as costs vary,
depending on several factors (raw water quality, size of scheme etc.). To meet their costs,
schemes
will
charge
up
to
€100
as
an
annual
membership contribution. After this, metered usage can be as high as €4.50 per 1,000 gallons
used over the ‘free’ allocation.
6. What level of contributions are householders typically making from their own
resources towards capital costs?
Again, this varies, but depending on the extent of capital works involved and the levels of
grant-aid available, householders on group water schemes are paying up to €1,200 as a direct
217
contribution to infrastructural upgrades. The average contribution would probably be in the
region of €600 a household. In some instances, where population density is low and where the
local contribution would otherwise be in excess of €1,200, CLÁR funding has been a
welcome addition.
7. Are all GWS receiving equal benefit under the different treatment solutions?
All schemes that comply with EU and National Procurement rules in pursuing an agreed and
approved upgrading strategy would appear to be receiving equal benefit. Where schemes
decide to pursue a go-it-alone upgrade and/or fail to follow the conditions required for
funding, the costs are borne entirely out of their own resources.
8. Are GWS households being dealt with equitably compared to urban dwellers?
No. Householders on public schemes have an unlimited supply of free treated water. They are
not required to make any direct contribution to capital works or the maintenance of their water
supply network. However, subsidy and State capital grants do redress the imbalance to some
extent.
9. What is the NFGWS view on the application of non-domestic user charging for water
across the different treatment solutions?
The NFGWS fully supports the principle of non-domestic charging, providing it is fair and
equitable and relates to cost and metered usage. We believe that this principle should apply,
irrespective of the different treatment solutions.
10. What is the NFGWS view on UFW levels in GWS and the cost implications? Would
universal metering of all GWS not provide better management information to address
UFW problems and also to ensure that Group Schemes are not subsidising individual
members overusing/wasting water?
The Federation is fully committed to dealing effectively with the unacceptably high UFW
levels identified on many group water schemes. We have resolutely pursued the adoption of
universal metering as a demand management tool, particularly in the context of DBO bundle
projects. To this end, all schemes involved in such projects (representing the vast bulk of the
sector) will be fully metered by 2009. We acknowledge the importance of the additional
financial supports towards achieving this objective. Furthermore, we believe that all schemes
have to move to universal metering and would welcome Department support in this regard, as
per our recent submission. We would add that there is a growing recognition amongst
schemes that universal metering is key to ending wastage and also to fairness in charging. The
NFGWS firmly believes that universal metering of schemes is the only way to avoid any
perception that one member is subsidising another. The charges put forward by committees
are generally agreed at an AGM of the members. As such, they must be fair and equitable,
and must be seen to be so. People should pay for what they waste/use and this is the advice
the Federation gives to schemes on an ongoing basis. We would be happy to forward
particular and incontrovertible evidence of the success of the Federation and of individual
218
schemes in significantly reducing UFW levels in recent years, both as a result of universal
metering and the introduction of effective leak detection strategies.
11. What is the likelihood
substandard distribution systems?
of
recontamination
of
treated
water
in
With regular maintenance and monitoring of chlorine residual the risk is low, but it cannot be
ignored. The focus of the Federation is on encouraging proper record-keeping on schemes and
we also plan to begin (later this year) delivering the NFGWS Quality Assurance Scheme on
GWS that have upgraded. Even with these efforts, however, there is little doubt that
replacement of substandard network will be the next major infrastructural challenge facing the
rural water sector. The concerns of the sector in relation to this issue are reflected in motions
adopted at our recent Annual Delegate Conference.
12. What is the NFGWS view on source protection measures and the effects of one off
housing, farming practices and septic tanks on water quality and subsequent treatment
costs?
The group scheme sector is pro-actively pursuing source protection as one of our key
objectives. We recognise that this is an issue that will grow in importance in the years ahead
and we are mindful of the fact that end-of-pipe solutions can never of themselves provide a
sustainable answer to water pollution. The NFGWS was instrumental in the establishment of a
National Source Protection Pilot Project, based in a group scheme source catchment, that
would be capable of roll-out across the GWS sector. This pilot is adopting a communitybased, low-technology approach to the issue and aims to harness local awareness of and
support for source protection initiatives. The project is currently examining the impact of
point and diffuse sources of pollution from farming and from septic tanks and early evidence
would suggest that the impacts may be site specific and that they may be remediated through
simple measures such as denying cattle direct access to a lake catchment, proper construction
and regular desludging of wastewater treatment systems and common sense. Where one-off
housing is regulated and particular attention is paid to the proper installation of wastewater
systems and their desludging, we feel that they are not incompatible with source protection.
We would also be keenly aware of the need to sustain the population base of rural
communities and recognise that one-off housing is a factor in achieving that sustainability.
The Federation will, however, wait for the final report of the Source Protection Project before
making a definitive evaluation of these issues.
13. What is the NFGWS view on continued funding for new GWS in view of the cost
implications of the Drinking Water Directives particularly for small schemes with
commercial connections?
Except in exceptional circumstances, new schemes should be funded only where they are
connecting to an existing treated supply, be that public or private. The Federation view is that
(depending on the scale of treatment required) very small schemes are simply not viable in the
context of maintaining compliance with the Drinking Water Directive and meeting the wider
regulatory and legislative demands on water suppliers. Where public or private suppliers have
219
proven capacity in their existing supplies, they should be obliged to facilitate the extension of
that supply to an unserviced area.
14. What legal provision is there requiring
connect in new GWS to their DBO plants in the future?
existing
DBO
Groups
to
We are not aware of any legal responsibility in this regard. However, it is generally the
practice of group schemes to welcome new members, subject only to the source, treatment
system and infrastructure being capable of servicing an expanded network. The NFGWS drew
up a Charter of Right and Responsibilities that has been adopted by schemes. This emphasises
that as a condition for claiming subsidy and where they have sufficient capacity, group
schemes must not deny a householder water. Perhaps existing capital grant aid might also be
looked at in regard to this issue, to deal with the small handful of schemes that will not
facilitate an extension to unserviced communities.
220
Appendix 4
20 November, 2006
Circular L9/2006.
To each County Manager
Value for Money Review of the Action Plan for Rural Drinking Water Quality 2003-2006
A Chara,
I wish to advise you that this Department has recently commenced a Value for Money Review of the
Rural Water Programme. This Review forms part of the 2006-2008 programme of Value for Money
Reviews approved by the Government in June 2006. The Review will focus on the implementation of
water quality upgrading solutions for Group Water Schemes, falling within the remit of the Drinking
Water Regulations, 2000, during the period of the Action Plan for Rural Drinking Water Quality 20032006. The Small Public Water and Sewerage Scheme and Well Grant elements of the Rural Water
Programme will not be reviewed as part of this study. The terms of reference for the Review (see
Appendix 1) are in line with Department of Finance guidelines.
As the administration of the Rural Water Programme is largely devolved to local authorities, the
efficiency and effectiveness of the local government system in meeting the objectives of the Action
Plan for Rural Drinking Water Quality 2003-2006 will be a central element of the Review.
Accordingly, as a first step in this Review, each local authority is asked to complete the attached
questionnaire. Local authorities are also welcome to make additional submissions, relevant to the
terms of reference of the Review. Individual local authorities will be contacted in the coming months
in relation to specific Group Water Schemes in their administrative area. Information already provided
in previous local authority returns, including the June 2006 Report to the European Commission, will
also be used as part of the Review.
The attached questionnaire has also been e-mailed to all Rural Water Liaison Officers. Local
authorities are asked to return the completed questionnaire (both by e-mail and signed hard copy) and
any other submissions by 15th December 2006. Submissions should be forwarded to Frank Gallagher,
Water Services Section, Block 1, Irish Life Centre, Lower Abbey Street, Dublin 1
(frankJ.Gallagher@environ.ie).
Frank Gallagher
Assistant Principal Officer
Water Services Section
Tel. No. 01-8882771
Cc: Rural Water Liaison Officers
221
Local Authority Questionnaire re. Rural Water Programme
This Review is focusing on the period of the Action Plan for Rural Drinking Water Quality
2003-2006 and the implementation of water quality upgrading solutions for Group Water
Schemes falling within the remit of the Drinking Water Regulations, 2000. All references to
Group Water Schemes in questions below (except Q.23, Q.24, Q25 & Q.26) only refer to
those schemes, which require water quality upgrading to comply with the Drinking
Water Regulations, 2000 i.e. schemes serving greater than 50 people. The references to
water quality upgrading solutions below refer to the five solutions identified in the June 2006
Report to the European Commission i.e. Design Build Operate (DBO), Non-DBO,
Connection to the public main, Takeover by local authority and Sterilisation/Disinfection.
Please provide a response to each of the questions below (using as much space as you need)
and e-mail the completed questionnaire to frankJ.gallagher@environ.ie by 15th December
2006.
Value for Money
Question 1
Did your local authority select the most economically advantageous water quality upgrade
solution for all Group Water Schemes in your administrative area (as specified in the Rural
Water Strategic Plan Guidance Documentation)?
Yes
No
If No, please state reason?…………………………………………………………
Question 2
Did your local authority carry out a comparison of the relative cost of building/upgrading a
water treatment facility for each Group Water Scheme (or sub-bundle of schemes) or
alternatively connecting the scheme(s) to an existing public water supply?
Yes
No
If No, please state reason? If there was insufficient available public water capacity, was the
option of increasing public water capacity considered and costed?
…………………………………………………………………….………….………
If Yes, please state where this information is documented?…………………………...
Question 3
Is competitive tendering being used in the procurement of all contractors for the
implementation of all water quality upgrading solutions (including necessary network
upgrades) for all Group Water Schemes in your local authority’s administrative area?
Yes
No
222
If No, please state reason?…………………………………………………………
Question 4
In all cases where it was decided to procure water treatment plants using DBO bundles, was a
technical/economic assessment of the possibility of connecting a number of Group Water
Schemes to the same treatment plant as a DBO sub-bundle considered?
Yes
No
If No, please state reason?…………………………………………………………
If Yes, please state where this assessment is documented?…………………………...
Implementation of the Action Plan for Rural Drinking Water Quality 2003-‘06
Question 5
What in your local authority’s view are the main obstacles to the full implementation of the
current Action Plan for Rural Drinking Water Quality?
…………………………………………………………………………………………
…………………………………………………………………………………………
Question 6
What additional measures if any, in your local authority’s view, are needed to fully and
successfully implement the current Action Plan for Rural Drinking Water Quality?
………………………………………………………………………………………
………………………………………………………………………………………
Question 7
It appears from the June 2006 Report to the European Commission, which was compiled
based on local authority information, that the two water quality upgrading solutions involving
connection to the public water supply i.e. “Takeover by local authority” (3 schemes
completed nationally) and “Connection to the Public Main” (6 schemes completed
nationally) have not been implemented at the same rate as other upgrading solutions e.g.
DBO.
Please provide reasons, if any, why there have been delays in implementing the “Connection
to the Public Main” upgrade solution in your county?
………………………………………………………………………………………
Please provide reasons, if any, why there have been delays in implementing the “Takeover by
local authority” upgrade solution in your county?
223
………………………………………………………………………………………….
Question 8
Please confirm the number of schemes completed for the above two upgrade solutions in your
County during the period of the Action Plan 2003-’06 (provide name of Group scheme and
month and year of completion in each case). In the case of takeovers, please indicate
whether the scheme taken over was on a public or private water supply at the time. If no
details are provided, a nil completion will be recorded for your County for the “Takeover by
local authority” and “Connection to the Public Main” upgrade solutions.
………………………………………………………………………………………………..…
………………………………………………………………………………..
Question 9
Please provide details in the box below of how many Group Schemes (approx) in your
administrative area are participating and not participating in the Action Plan for Rural
Drinking Water Quality in implementing a water quality upgrade solution for their scheme?
Participating
Not Participating
No. of Group Water Schemes
Total No. of Households (approx)
Please state reasons given by Group Schemes for non-participation
…………………………………………………………………………………………
Question 10
Please provide details in the box below of how many Group Schemes, who are not
participating in the Action Plan for Rural Drinking Water Quality, are in receipt of an
operational costs subsidy from the Rural Water Programme.
Non-participating Schemes
No. of Group Water Schemes
No. of Households (approx)
Receiving Subsidy
Not receiving subsidy
Monitoring of the Action Plan for Rural Drinking Water Quality
Question 11
In schemes where water quality upgrading solutions have now been completed, what
monitoring measures have your local authority implemented to verify that the water coming
out household taps in those Group Schemes now fully comply with the Drinking Water
Directive on a sustained basis?
…………………………………………………………………………………………
…………………………………………………………………………………………
224
Question 12
Do all Group Water Schemes in your County, where water quality upgrading solutions have
been completed, as per the June 2006 Report to the European Commission, now fully comply
with the Drinking Water Directive?
Yes
No
If No, please state reasons and provide details of numbers of compliant and non-compliant
completed Schemes below? Please also state any risk factors, which could cause currently
compliant upgraded schemes to become non-compliant again.
…………………………………….…………………………………………………..
…………………………………………………………………………………………
Compliant
Non-Compliant
No. of upgraded Group Water Schemes
Total No. of Households (approx)
Question 13
What initiatives have your local authority taken to encourage Group Water Schemes to
implement improved source protection measures?
…………………………………………………………………………………………..
Water Demand and Unaccounted for Water (UFW)
Question 14
How does your local authority calculate the maximum allowable plant capacity, when
authorising the design and construction (or upgrade) of a water treatment facility for a group
water scheme(s)? Please specify the maximum domestic water allowance per house when
calculating plant design capacity.
…………………………………………………………………..………………………
…………………………………………………………………………………………..
Question 15
What is the maximum level of unaccounted for water, which your local authority permits
when authorising the design and construction (or upgrade) of a water treatment facility for a
group water scheme(s)?
…………………………………………………………………..………………………
…………………………………………………………………………………………..
Question 16
What measures have your local authority taken to encourage group water schemes to reduce
their level of UFW?
…………………………………………………………………..………………………
225
…………………………………………………………………………………………..
Water Charging for Group Schemes connected to the Public Water Supply
Question 17
Are domestic Group water users charged for their water supply?
Yes
No
Question 18
Are non-domestic Group water users charged for their water supply?
Yes
No
Question 19
How is water usage by domestic and non-domestic Group Scheme consumers measured?
…………………………………………………………………………………..
…………………………………………………………………………………..
Question 20
Are Group Water Scheme non-domestic users charged for water on the same basis as nonGroup Water Scheme non-domestic customers e.g. commercial customers in urban centres?
Yes
No
If No, please state reasons.
…………………………………………………………………………………………
…………………………………………………………………………………………
Question 21
Please provide details of your authority’s current charging levels for Group Scheme domestic
and non-domestic users in the box below. If different Group Water Schemes are charged at
different rates, please explain in the space below. Mark N/A, where not applicable.
Domestic User
Non-Domestic User
Connection Fee per house (€)
Fixed Charge per house (€)
Variable/Volumetric Charge(€ & qty)
Free Water Allowance (quantity)
Other Charge (please specify)
……………………………………………………………………………………….
Question 22
Does your local authority’s water charging system recover your full costs in providing water
to Group Scheme customers?
Yes
No
226
If No, please state reasons.
…………………………………………………………………………………………
New Schemes, Network Upgrades and Subsidy Payments for all Group Schemes
Please provide details in relation to all Group Water Schemes for the last four questions
(Q23 – Q26) not just Group Water Schemes serving greater than 50 persons.
Question 23
Please provide details of all newly established Group Water Schemes that have received
approval for funding i.e. current (subsidy) and/or capital funding (network or water quality
upgrade) for the first time from your local authority during the period of the Action Plan for
Rural Drinking Water Quality 2003-2006? Where a new Group Scheme received funding
over more than one year, only include/count the Group Scheme and its houses in the first year
of funding approval.
Year of
first
funding
approval
No. of new
Group Schemes
with a private
source
Total no. of
houses in new
Group Schemes
with a private
source
No. of new
Group
Schemes with
a public
source
Total no. of
houses in new
Group Schemes
with a public
source
2003
2004
2005
2006
Question 24
Please provide details of all existing Group Water Schemes that have received funding for an
extension by your local authority during the period of the Action Plan for Rural Drinking
Water Quality 2003-2006? Where a Group Scheme received extension funding over more
than one year, only include/count the Group Scheme extension and its additional houses in the
first year of funding approval.
First year
of
extension
funding
approval
No. of
extended
Group Schemes
with a private
source
Total no. of
new houses in
extended
Group Schemes
with a private
source
No. of
extended
Group
Schemes with
a public
source
2003
2004
2005
2006
227
Total no. of new
houses in
extended Group
Schemes with a
public source
Question 25
Please provide details of all existing Group Water Schemes i.e. (not new Group Schemes),
which have received a pipe network upgrade during the period of the Action Plan for Rural
Drinking Water Quality 2003-‘06? Where a Group Scheme received network upgrade funding
over more than one year, only include/count the Group Scheme and its houses in the first year
of funding approval.
First year
of pipe
upgrade
approval
No. of existing
private Group
Schemes which
received pipe
network
upgrades
Total no.
of Houses
in
upgraded
private
Schemes
No. of existing
public Group
Schemes which
received pipe
network
upgrades
Total no.
of Houses
in
upgraded
public
Schemes
No. of Scheme
network upgrades
(in Columns 2&4
of this table)
unrelated to
water quality
upgrade solutions
2003
2004
2005
2006
Question 26
Please provide details of the number of Group Water Schemes and houses in receipt of the
different levels of subsidy during the 2003-’06 period in the table below?
Subsidy for houses
supplied by local authority
source (€50.79 max)
No. of
No. of Total
Schemes Houses Subsidy
Paid (€)
Subsidy for houses
supplied from private
source (€101.58 max)
No. of
No. of Total
Schemes Houses Subsidy
Paid (€)
Subsidy for houses with a
DBO/O&M treatment
contract (€196.81 max)
No. of
No. of
Total
Schemes Houses
Subsidy
Paid (€)
2003
2004
2005
2006
Thank you for completing the above questionnaire. The questionnaire respondent is asked to
provide their name and details in the space provided below.
Name: ………………………………………………………………………………
Official Title:……………………………………………………………………….
228
Date: ………………………………………………………………………………..
E-mail address:……………………………………………………………………..
Contact telephone No………………………………………………………………
The Department may need to contact you again in relation to expenditure on specific Group
Water Schemes in your administrative area. If there are any further issues that you wish to
raise in relation to the implementation of the Action Plan for Rural Drinking Water Quality
2003-2006, please provide details on subsequent pages.
Local authorities are asked to return the completed typed questionnaire and any other
submissions by 15th December 2006. Completed questionnaires and submissions should be emailed to Mr. Frank Gallagher (frankJ.Gallagher@environ.ie), Water Services Section, Block
1, Irish Life Centre, Lower Abbey Street, Dublin 1 (tel. No. 01-8882771).
229
Appendix 5
Drinking Water Regulations 2000 – Water Quality Parameters
230
Appendix 6
Table 4.1.5 - % Non-Domestic Water Demand (approximate) for DBO Bundles
%Non
%Non
Domestic
East Cavan DBO
Limerick DBO
Consumption
Domestic
Consumption
Billis Lavey
57%
Baggottstown
59%
Bunnoe
52%
Ballinvreena
70%
Dhuish
57%
Ballybricken
50%
Drumkeery
60%
Ballyduff
71%
Kill
52%
Ballyorgan
61%
Mountain Lodge
72%
Bulgaden
67%
Crosserlough
40%
Caherline/Newtown
52%
Clifferna
54%
Cappagh
53%
Dernakesh
39%
Carnane
36%
Glaslough Tyholland
45%
Coshma/Killeen
46%
Croagh/Farradonnelly
46%
Glenroe
30%
South West Cavan
Erne Valley
82%
Glenstal
56%
Lavagh/Ballyheelan
38%
Granagh
68%
Crossdoney GWS
71%
Griston
75%
Kiltale
58%
Kileedy
76%
Kilfinny
60%
Lough Gur
63%
Galway DBO 1
Ardrahan
52%
Ballyglass/Fiddane
60%
Brierfield
49%
Sligo East DBO
Caherlistrane
51%
Geevagh/Highwood
60%
Cleggan/Claddaghduff
29%
Keash
56%
Cloonatleva
55%
Culfadda
45%
Cloonluane
6%
Corrick
25%
Inis Meain
49%
Castlebaldwin
46%
Kiltevna
45%
Toberowen Lissybroder
45%
Lettergesh
13%
Lowville
50%
Milltown
56%
231
New Inn
55%
%Non
Mayo DBO No. 1
Domestic
Consumption
Monaghan DBO
Ballycroy
45%
Aughnashavley
22%
Ballyglass/Carnacon
65%
Barraghy
Belderrig
43%
Churchill/Oram
51%
Bohola
36%
Corduff
24%
Brackloon/Spaddagh
55%
Donaghmoyne
Drummin
32%
Doohamlet
34%
Glencorrib
35%
Drumgoole
69%
Glenhest
43%
Inniskeen
Killeen
40%
Killanny
Kilmeena
21%
Newbliss
Kilmovee
35%
Smithborough
Laghta
26%
Stranooden
Lough Mask Creevagh
47%
Truagh
Fahy Drumindoo
32%
Tydavnet
No Data
No Data
No Data
5%
No Data
14%
7%
15%
No Data
Source: Figures derived from DBO Client Representative data – January 2007
232
Appendix 7
Provisional Design Build (DB) Costs for completed DBO Bundles – April 2007
West Cavan DBO
Scheme Names
Glangevlin
Doobally
Ballymagovern/Corran
Corlough
Sralaghan
Kildallan
Milltown
Gowlan
Bawnboy Public WS
No. of
Houses
Totals
East Cavan DBO
Scheme Names
Billis Lavey
Bunnoe
Dhuish
Drumkeery
Kill
Mountain Lodge
Crosserlough
Clifferna
Dernakesh
Glaslough Tyholland
Total
SW Cavan DBO
Scheme Names
Erne Valley
Lavagh/Ballyheelan
Crossdoney GWS
Kiltale
Totals
Capital
Capital Cost
Total Capital Cost per
per
Population DB Cost
House
population
145
435
€837,130
€5,773
€1,924
52
156
€817,846
€15,728
€5,243
115
345
€609,185
€5,297
€1,766
297
891
€1,241,558
€3,706
€1,235
38
114
230
690
€776,705
€3,377
€1,126
312
936
€989,837
€3,173
€1,058
150
450
€1,114,576
€7,431
€2,477
66
198
€714,315
€10,823
€3,608
1,405
Population Houses
1,290
480
615
1,269
285
1,122
1,638
1,329
561
1,590
10,179
No. of
Houses
4,215
€7,101,151
Cost per
Cost per
Total DB Cost House
person
430
€1,052,992
€2,449
€816
160
€782,600
€4,891
€1,630
205
€1,365,723
€6,662
€2,221
423
€918,441
€2,171
€724
95
€880,049
€9,264
€3,088
374
€786,450
€2,103
€701
546
€400,536
€734
€245
443
€293,158
€662
€221
187
€335,461
€1,794
€598
530
€469,403
€886
€295
3,393
€7,284,812
Capital
Total Capital Cost per
Capital Cost
Population DB Cost
House
per person
1,011
3,235
€1,801,609
€1,782
€557
369
1,181
€751,258
€2,036
€636
255
816
€896,562
€3,516
€1,099
180
576
€574,154
€3,190
€997
1,815
5,808
233
€4,023,583
Clare DBO Scheme
Names
Lissycasey
Killone
Toonagh/Dysart
Kilmaley/Inagh
No. of
Houses
Totals
Monaghan DBO
Scheme Names
Aughnashavley
Barraghy
Churchill/Oram
Corduff
Donaghmoyne
Doohamlet
Drumgoole
Inniskeen
Killanny
Newbliss
Smithborough
Stranooden
Truagh
Tydavnet
Total Capital Capital Cost
DB Cost
per House
772 €1,930,655
€2,501
185 €1,058,030
€5,719
328 €1,732,267
€5,281
1,555 €1,696,265
€1,091
2,840
€6,417,217
Population
served
Houses
1300
No Data
No Data
900
1100
No Data
700
900
650 No Data
1400
434 No Data
300 No Data
2600 No Data
1384
2040
Cost per
DB Cost
House
414
€628,172
€1,517
€83,200
286
€556,693
€1,946
314
€736,224
€2,345
800
€835,489
€1,044
220
€670,296
€3,047
257
€722,211
€2,810
€581,497
620
€739,447
€1,193
€548,573
€43,136
€51,033
395
€872,833
€2,210
685
€777,423
€1,135
3,991
Total
€7,846,228
NW Sligo DBO Scheme No. of
Names
Houses
Ballintrillick
Beltra
Benbulben
Castletown
Drum East
Keelogyboy
Total DB
DB Cost per
Cost
House
98
€294,628
€3,006
80
€360,351
€4,504
66
€273,346
€4,142
58
€264,402
€4,559
260
€360,041
€1,385
106
€272,961
€2,575
Totals
668
€1,825,729
234
East Sligo DBO Scheme No. of
Names
Houses
Geevagh/Highwood
Keash
Culfadda
Corrick
Castlebaldwin
Totals
Mayo Bundle No. 1
Ballycroy
Ballyglass/Carnacon
Belderrig
Bohola
Brackloon/Spaddagh
Drummin
Glencorrib
Glenhest
Killeen
Kilmeena
Kilmovee
Laghta
Lough Mask Creevagh
Fahy Drumindoo
Total DB
Capital Cost
Capital Cost per House
501
€849,192
€1,695
140
€467,787
€3,341
194
€205,634
€1,060
126
€383,735
€3,046
330
€710,274
€2,152
1,291
Population
828
1,221
150
2,145
457
148
1,025
250
646
1,242
2,230
301
1,049
2,125
Total
Galway DBO No. 1
Schemes
Ardrahan
Ballyglass/Fiddane
Brierfield
Caherlistrane
Cleggan/Claddaghduff
Cloonatleva
Cloonluane
Inis Meain
Kiltevna
Toberowen Lissybroder
Lettergesh
Lowville
Milltown
New Inn
Rinn Killeeneen
Totals
€2,616,622
Houses
DB Cost
325
366
55
574
150
46
337
146
208
320
523
98
325
652
€750,404
€731,109
€105,132
€243,201
€628,843
€475,381
€516,317
€481,465
€552,261
€668,784
€803,221
€513,039
€675,623
€1,110,293
4,125
€8,255,073
Cost per
House
€2,309
€1,998
€1,911
€424
€4,192
€10,334
€1,532
€3,298
€2,655
€2,090
€1,536
€5,235
€2,079
€1,703
Cost per
person
€906
€599
€701
€113
€1,376
€3,212
€504
€1,926
€855
€538
€360
€1,704
€644
€522
Population
DB Cost
DB Cost per
No of Houses Served
Total D&B Cost per House person
157
447
€398,011
€2,535
€890
98
313
€369,131
€3,767
€1,179
64
223
€370,675
€5,792
€1,662
867
3200
€1,016,863
€1,173
€318
240
€1,447,225
€6,030
76
280
€396,758
€5,220
€1,417
150
495
€366,968
€2,446
€741
117
200
€343,726
€2,938
€1,719
83
250
€128,771
€1,551
€515
192
100
51
350
317
91
2,953
578
313
145
1541
1049
269
5,120
235
€297,879
€371,838
€334,424
€1,133,774
€500,639
€367,823
€7,844,505
€1,551
€3,718
€6,557
€3,239
€1,579
€4,042
€515
€1,188
€2,306
€736
€477
€1,367
Glinsk Creggs DBO
(Galway)
Glinsk Creggs GWS
Population
DB Cost
DB Cost per
No of Houses Served
Total D&B Cost per House person
320
1,000
€977,130
€3,054
€977
Limerick DBO Scheme
Names
Houses
Baggottstown
Ballinvreena
Ballybricken
Ballyduff
Ballyorgan
Bulgaden
Caherline/Newtown
Cappagh
Carnane
Coshma/Killeen
Croagh/Farradonnelly
Glenroe
Glenstal
Granagh
Griston
Kileedy
Kilfinny
Lough Gur
Total
Total DB
Costs
Cost per house
45
€135,540
€3,012
67
€178,301
€2,661
187
€352,088
€1,883
26
€153,863
€5,918
35
€184,378
€5,268
103
€310,591
€3,015
212
€120,974
€571
175
€350,351
€2,002
329
€238,755
€726
95
€217,098
€2,285
36
€198,017
€5,500
32
€170,594
€5,331
90
€171,484
€1,905
140
€333,852
€2,385
32
€173,729
€5,429
199
€721,471
€3,625
209
€180,105
€862
501
€603,065
€1,204
2,513
4,794,256
Source: DBO Client Representatives
236
Appendix 8
Ryan Hanley Submission re. Leakage Control – 14th March 2007
Dear Frank,
I refer to our phone discussion of last week during which we discussed the evolution, during Bundles
no 1 in Mayo and Galway, of our approach to the necessary control of Unaccounted for Water and the
interrelationship in achievement of this goal between critical mains identification based primarily on
burst frequency and their early replacement during the procurement of the DBO plant in conjunction
with the provision of water conservation infrastructure i.e. district meters, PRVs, valves and consumer
meters.
The realization of such critical mains replacement and water conservation infrastructure as a precursor
to their subsequent use in the conduct of Leakage Control surveys has proved vital to the arming of
GWS committees with the tools to permit them control their water usage.
Active leakage control involving implementation of the findings of the Leakage Control Survey has
allowed GWS to control their O&M costs from the start of the O&M period and in some cases, where
existing daily demand outstripped 2025 Design daily demand + 25% UFW, permits the DBO
Contractor


to commission the DBO Plant and to supply treated water without the use of process bypasses
carrying untreated or partially treated fractions to supply
to take over the O & M of the plants which he otherwise could not.
I prepared a Table setting out the history of UFW management since the original Preliminary Report
Water Audit which is attached for a selection of schemes in Mayo and Galway Bundles Nos 1. This
table in conjunction with the Bundle Leakage Control Strategies sent to you previously and the
selection of attached site specific Leakage Control Survey Reports (for Ardrahan and Rinn Killineenen
GWS in Galway) sets out the methodology of this approach and the level of detail emanating from
these surveys to permit GWS to address the problem.
The attached Table of Leakage Survey findings and the appended comments will also give you a
flavour for the range between the wonderful success of committees who have been and continue to be
active in the implementation of the Leakage Survey findings compared with the failure of some GWS
to manage UFW where apathy and inactivity prevails. The effect of such inactivity on the timely
completion of the DB phase of the DBO contract can also be seen. In addition the Table seeks to show
that there is a large cost in all instances, associated with the application of tendered O&M variable
charges by the DBO operator. The range of cost that will be incurred by individual GWS if their
inactivity continues to result in a failure to manage UFW is also set out. Such high costs I predict will
yet spurn the inactive into active demand management.
You also expressed concern regarding costs incurred on network improvement works associated with
these GWS and the optimum timing of such upgrade works.
In evolving our approach to the second bundles in Mayo in Galway, which attempts to learn from our
experiences in the first bundles, the following is the sequence of works which we believe will best
facilitate the goal of necessary UFW control to permit construction of treatment processes sized at
2025 demand + 25% while also accommodating the ongoing phasing of network upgrade works to
accommodate within existing networks the growth in daily water demands to 2025.
237
1)
2)
3)
4)
5)
identification of critical mains replacement based on high burst frequency or grossly
inadequate hydraulic capacity which limit quality of supply
Inclusion of such critical mains for each bundle scheme into an early Advance Works
Scheme(s) with necessary metering and water conservation infrastructure, to be procured
and executed during the procurement, design and Part 8 planning phases of the main DBO
Contract.
In the case of the second Mayo and Galway bundles, the scoping, procurement and
execution of separate advance works contracts for the necessary pipework interconnection
of amalgamating schemes where the Bundle Rationalisation Report shows that a shared
DBO treatment plant offers better value to the exchequer than discrete scheme plants
Following the phased realistion of works on schemes provided with critical mains
replacement and water conservation infrastructure, as in 2) above, undertake Leakage
Control Surveys on each scheme to determine the factor of overall daily demand
attributable to leakage in the GWS distribution network compared to the quantity wasted
daily by consumers on their side of each boundary box. This survey will serve two
purposes namely
 the identification of remaining network sections with excessive leakage together with
the names and location of consumers which are excessively wasting water
 the on site hands on training of GWS personnel in the active leakage management
The ongoing achievement of the leakage targets by GWS, as evident in some of the
Bundle 1 Leakage surveys, in addition to helping management of daily demand below the
design demand, will free up hydraulic capacity in the existing distribution pipework
previously suffering a reduction in service level consequent from excessive headlosses
incurred by the conveyance of leaking and wasted water.
It is recommended where and when the leakage surveys identifies further critical mains
necessary for GWS to control water usage or improve levels of service without the use of
excessive pressurization of mains, a further network rehabilitation contract including
these critical mains should be scoped. The design and construction of such rehabilitation
works should be undertaken only on the basis of full knowledge of the condition and
performance of the existing network and with a view to the future requirements for
upgrading necessary to distribute the 2025 daily demand + 25%. It is recommended that
such rehabilitation works should be sized using a hydraulic model distributing above
future design daily demands
Using this approach would ensure that decisions regarding the sequencing of works would be
made based on sound engineering reasons and designed to achieve the goal of UFW Control
thereby permitting the DBO process to progress without impediment while at the same time
claiming back available hydraulic capacities in existing distribution networks. Having reduced
UFW towards target levels, decisions regarding the replacement of critical mains for leakage or
hydraulic reasons could be sensibly progressed based on the use of hydraulic models which would
properly size the pipes for the particular level of UFW and the condition of mains pertinent to each
network. It should not be forgotten that existing networks were often designed and installed 20-30
years ago to accommodate daily demands that have already been grossly exceeded
notwithstanding their inability to distribute the larger future 2025 daily demand + 25%
I hope you will find the foregoing useful to you in the finalization of your report.
Please do not hesitate to contact me if you need anything further.
MICHAEL JOYCE
Director
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Appendix 9
Membership of Departmental Rural Water Review Steering Committee
Mr. Terry Allen – Principal Officer (Chairperson)
Mr. Carthage Cusack – Assistant Principal
Mr. John Fitzgerald – Engineering Inspector
Mr. Frank Gallagher – Assistant Principal (Lead Reviewer)
239
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L7/97 - Water Distribution Network Management and Leakage Control
L4/98 – Rural Water Programme
L16/2002 – Water Pricing Framework
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242
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Relevant Websites
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Websites - www.environ.ie
Environmental Protection Agency – www.epa.ie
European Commission – www.europa.eu
European Court of Justice (ECJ) fines (http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/05/482&format=HTML&a
ged=0&language=EN&guiLanguage=fr)
Irish Legislation (primary and secondary) – www.irishstatutebook.ie
Irish Draft Legislation – www.oireachtas.ie
National Federation of Group Water Schemes – www.nfgws.ie
Scottish Executive-http://www.scotland.gov.uk/Topics/Environment/Water/pws/pws1
Scottish Executive - http://www.privatewatersupplies.gov.uk/
Water Services National Training Group - www.wsntg.ie
Web-based European Knowledge Network on Water –http://www.weknowwaternetwork.com
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