THE EPA WILL ASK YOU TO COUNT THE NUMBER OF SAMPLES AND USE THE PERCENTAGE OF SAMPLES THAT HAVE FAILED AS A GUIDE TO HOW POLLUTED OUR WATER IS. WE ARE COUNTING THE NUMBER OF WATER SCHEMES WHICH ARE POLLUTED EACH YEAR. HOW TO UNDERSTAND THE EPA WATER QUALITY FIGURES
The figures are as simple as this. The law (EU directive) says the limit for coliforms (COLIFORMS we repeat, that includes faecal coliforms) is nil. This is the MAC value (Maximum Allowable Concentration), so called, and its NIL, for both EU and W.H.O.
To prove the figures do the following:
1. Get the EPA reports for appropriate year(s).
2. Get a pencil.
3. Count the total number of supplies (Group and Council run) for each county.
4. Count the number of supplies with any exceedance of Coliforms in each
county (forget number of samples, this is irrelevant). Just count all
5. Divide the number of supplies which have exceedances by the total number
of supplies and multiply by 100.
6. You will get a figure of 45% approx.
We defy anyone to prove us wrong on this. There's no trickery with numbers ; we've triple checked the calculations before we published them. Its just basic arithmetic. But even the EPA is convinced by its own propaganda that things could never be this bad.
REMEMBER THE EPA WILL ASK YOU TO COUNT THE NUMBER OF SAMPLES AND USE THE PERCENTAGE OF SAMPLES THAT HAVE FAILED AS A GUIDE TO HOW POLLUTED OUR WATER IS. WE ARE COUNTING THE NUMBER OF WATER SCHEMES WHICH ARE POLLUTED EACH YEAR.
This appeal seeks to bring into force a standard testing of existing septic tanks when extensions are applied for. The local authority has sought further information from the applicant. County Secretary,
Development: to renovate and extend dwelling house at Knocknacarrow Townland, Cootehall, Co. Roscommon.
Applicant: Breifne Consultants, Engineering Consultants, Leitrim Village, Co. Leitrim on behalf of Sean Dogherty
Application lodged: 12/09/01; Additional Information Requested: 08/11/01; 07/02/02
This application is situated in a prominent site of High Visual Amenity, particularly with regard to the Navigation approach to Cootehall from Lough Edin where the existing structure to which an addition is proposed is a notorious eyesore in this relatively unspoiled and protected landscape.
This river/lake network is ~ major natural tourism resource of County Roscommon and is recognised as such by the following publications:
¬? Roscommon County Development Plan 1993
¬? Roscommon County Draft Development Plan 2000
¬? Brady Shipman Martin Lough Key Study Report, 1981
¬? Draft Lough Key Plan 3448 commissioned by Roscommon County Council to supercede the Lough Key Study Report 1981.
The application involves the virtual reconstruction of the existing house. However, the plans and specifications are inadequate in providing an indication of the plan and elevation distinction between what is existing and what is proposed. We would submit that in order to properly assess a planning application for the alteration and extension of an existing dwelling house that clear comparison by means of existing plans and elevations and proposed plans and elevations should be provided.
Because of this inadequate comparison, a visual impact analysis of the proposal is not feasible. Given the intrusive and incongruous nature of the existing structure, such an analysis is critical. A fundamental redesign of the structure may be necessary to achieve the requirements of the Development Plan.
The specification of detailing and materials is inadequate in allowing the design quality and environmental sustainability of the proposed building materials to be assessed. It is particularly undesirable that the specifications should refer to an either/or option of double glazed uPVC or hardwood windows without addressing the environmental sustainability and visual impact of either building material.
It is also unclear from examining plans and specifications what the extent of the increase is in bedroom and plumbing capacity proposed alterations. Is the profile of the house to be raised?
Accordingly, an appraisal of the adequacy and performance of the existing septic tank and percolation area should be carried out to establish if any re- Medial measures will be required to accommodate the proposed development. This is particularly important given the naturally poor drainage in this area demonstrated in other appeals against decisions by your authority in the townlands of Granny, Torreymartin, and Killamcarrill.
Finally, it is recommended that any consideration of extension proposals to any existing houses in Areas of High Visual Amenity should first examine the original landscaping conditions to determine if the required protection of the visual amenities was implemented. Should the planning authority determine to permit this proposal, it now has the opportunity to secure the proper planing and development of the area through the most stringent landscaping, environmental and design conditions.
We would remind the local authority of our submission of 9 October, 2000, in which we detailed the failure of ten developers to adhere to the conditions of the planning conditions in relation to screening these developments from the River Shannon by the use of native hedgerows whose retention and augmentation is rightly a standard condition of development consent of your authority in sensitive areas
We recommend that further information be sought from the applicant to address these issues.
Peter Sweetman and Associates and on behalf of Friends of the Irish Environment
Quality of group water schemes continues to deteriorate in EPA figures and show in the words of the EU Infringement proceedings "widespread and persistent breaches of the micro-biological standards". 44% of Group Water Schemes are contaminated in the latest figures.
Figures showing contamination by number of samples are irrelevant as clean supplies like Dublin are tested every day and some Group Water Supplies are not even tested once a year.
Government spending is concentrated on treatment, not source protection.
The quality of the water at source continues to decline through slurry spreading, overgrazing, and ill sited and ill maintained septic tanks generated by development in advance of infrastructure, suburbanization and ribbon development.
There is no requirement for compliance for Group Water schemes to meet EU Standards - merely "improvement" in the meaningless "as soon as possible". There is no penalty for non compliance. There is no legal responsibility for Group Water Schemes.
Recent legislative changes do not answer these grounds of the EU infringement proceedings, which has called this problem a "serious public health concern."
Chemical treatment poses its own dangers when protection at source could give perfect quality water for zero capital and maintenance costs.
Chlorine based treatments do not affect cryptosporidium, now recognized as a serious cause of biological contamination both through drinking water and through contamination of food products which could undermine the quality and reputation of Irish food.
We have no inventory of the number or location of the boreholes in Ireland.
We have no Guidelines for drilling of bore holes, especially relevant with the large sums of money available to local authorities to seek new sources of water. Cowboy drillers engage in poor practices, leaving unsuccessful holes open which may introduce contamination; they can drill through multiple aquifers, spreading contamination.
The availability of money makes attractive fast fix options involving unnecessary engineering works, big concrete reservoirs and new pipelines when the natural reservoirs underground - aquifers - may already be there.
The Government refuses to make gastro enteritis a notifiable disease, obscuring analysis of the water quality problems and human health.
We would draw the Study's attention to the European Economic Community Directive 91/271/EEC of 21 May, 1991 concerning urban waste-water treatment and its relationship to development control. Our reading of this Directive is that by virtue of its expansion and the sensitivity if its location Killarney is an "agglomeration" which requires the collection and treatment of waste water under this Directive. We would draw the Study's attention to the European Economic Community Directive 91/271/EEC of 21 May, 1991 concerning urban waste-water treatment and its relationship to development control.
Our reading of this Directive is that by virtue of its expansion and the sensitivity if its location Killarney is an "agglomeration" which requires the collection and treatment of waste water under this Directive. We note that the permanent population in 1996 of the Urban District was 8,809 and Rural District 26,501, the combination being more than one quarter of the population of the County 126,130.
An agglomeration is defined in Article 2 (4) as "an area where the population and/or economic activities are sufficiently concentrated for urban waste water to be collected and conducted to an urban waste water treatment plant or to a final discharge point". The concentrated density and contiguous nature of the recent developments in the area reinforce this definition.
The current capacity of the Killarney treatment plant is, with the recent expansion, 42,000 pe. While the population of "Killarney" is approximately 9,000 pe., servicing tourism, the principal industry, currently places demands on the treatment plant at the height of the season of between 37,000 and 40,000 pe.
Killarney is, further, a "sensitive area" under this Directive and is only one of four Loughs so designated in the Irish Implementing Regulations as it contains a natural freshwater lake which has been found to be eurtrophic.
The Directive has particular regard to eutrophication, defined in Article 2 (11) as "the enrichment of water by nutrients, especially compounds of nitrogen and/or phosphorus, causing an accelerated growth of algae and higher forms of plant life to produce an undesirable disturbance to the balance of organisms present in the water and to the quality of the water concerned." The recent history of the closure of Lough Leane from toxic algae blooms refers.
The high permeability of the geology of the area reinforces the sensitivity of the catchment and the relationship between waste water and eutrophication has been well established
Even within the geographic circle formed by the present collection system because of the topography there are significant sources of waste water which can not be collected without further investment.
In these circumstances, the Department of the Environment is obliged under the Directive to prioritize the allocation of sufficient finance to ensure facilities for centralized collection and stringent treatment of all waste waters for the agglomeration of Killarney, both within and without any jurisdictional or geographic boundaries as they have no relevance to the Directive.
We present to your study team the argument that any further development consent, commercial or domestic, within the Killarney agglomeration would result in a breech of the Directive.
This argument forms the grounds for an infringement proceeding against Ireland which can only be answered by allocation of finance from the Department of the Environment. When compliance with the Directive is so clearly in the best interest of the proper planning and development of Killarney and County Kerry, we can see no reason why such a proceedings should be required.
We request the right to make an oral presentation on this matter at which the appropriate Local Authority personnel could also be present.
"He who doesn't want to hear must feel!" Private letter to the Editor of the Irish Times 12.01.00
The Managing Editor,
The Irish Times
12 January, 2000
You will remember that we contacted you in February 1998 concerning the gross under-reporting by your paper's Science correspondent on the subject of contaminated drinking water in Ireland.
After several faxes and letters, you flatly denied any misinterpretation by your paper and refused to enter into any further discussion with us on the subject. This was despite the fact that our researcher has spent the last 5 years researching this issue in Ireland and despite the ongoing investigation by DG XI of the European Commission.
Your paper today demonstrates the end-effect of your reluctance to investigate our claims, i.e. Ireland is now being taken to court by the European Commission for contaminated drinking water supplies. The basis of the Commission's case is our complaint to them and the research material we tried to show to you in 1998.
In effect, your paper has
A/ failed to honestly and scientifically investigate this issue in the first place,
B/ failed to highlight the real problem to the public and put the issue into the political arena,
C/ has done so to perpetuate the Celtic Tiger "spin" we are all expected to believe.
We have to say this: "We told you so". The effect of your paper ignoring our claims is that Ireland will now be dragged through the European Court, and faces a fine in the order of a quarter of a million pounds per day (!). The country's reputation for having a clean environment will be inevitably damaged.
Thus, the failure of your paper to confront this issue by failing to adequately report it in the first place will now have the inevitable effect of damaging Ireland's interests.
There is an Old Dutch saying which goes as follows: "He who doesn't want to hear must feel!"
Ireland is about to feel the wrath of the European Court in Luxembourg, with or without the honest reporting of your paper.