Submission in relation to sewage treatment plant in Clonshaugh and effluent outfall at Ireland’s Eye

  1. Site notices

There were no site notices at the land locations nearest to the outfall nor at the locations where people take boats to get to the waters into which the effluent will be discharged. Clearly there should have been site notices on Ireland’s Eye and Howth Harbour.

  1. Impact on water users

I contacted Irish Water some time ago pointing out that the waters around Ireland’s Eye are used for a wide range of activities (swimming, sailing, kayaking, scuba diving, lobster and other fishing) and asking that all of these groups be considered and consulted. Despite that I can find no mention of some of these activities in the EIAR (e.g. scuba diving and kayaking). There is no meaningful assessment in the EIAR of the impact of the effluent outfall on the water quality in which these activities take place.

The EIA needs to assess the impact on all water users who are entitled to continue to use the water in Portmarnock, Balscadden and Ireland’s Eye which is currently of excellent quality. This has not been done in the EIAR.

  1. Inadequate modelling

Either the modelling itself is inadequate or the results have been inadequately presented.

The area into which the effluent will be released has excellent water quality. The water quality at Portmarnock is almost always excellent and often at the lower limits of detection. As a result it has the only Blue Flag in the Dublin area. All of the tests at Balscadden and Ireland’s Eye have come back at the lower limits of detection. (Fingal’s water testing at Balscadden and Ireland’s Eye came about in part due to local concerns at the potential impact of this proposed outfall.)

Irish Water wouldn’t release any of their water quality studies in advance of submitting the planning application which unfortunately they did at the end of June, leaving the public with the holiday period to look at it.

E.coli levels at Balscadden and Ireland’s Eye are always <10 MPN/100ml. In the standards, <250 is “Excellent”, so it’s 25 times cleaner than “Excellent”. Intestinal enterococci results are <1 CFU/100ml, to be compared with an “Excellent” standard of <100ml. So the water quality is 100 times cleaner than excellent by that metric.

Irish Water appear to have wrongly assumed that the standard to be met is 500 and that they are not required to always maintain excellent quality where it exists:

“The Bathing Water Quality Regulations 2008 (S.I. No. 79 of 2008) require that the maximum values of Escherichia coliforms should not exceed the mandatory value of 500/100ml in 95% or more of the samples taken in the season to ensure a ‘good’ classification of bathing water beaches.”

(Chapter 8 Marine Water Quality,https://www.gddapplication.ie/planning-sites/greater-dublin-drainage/docs/environmental-documents/volume-3a/Chapter%208%20Marine%20Water%20Quality.pdf)

The analysis presented by Irish Water in their EIS has its minimum cut off at 250 MPN/100ml. The analysis carried out with a minimum graphic representation of 250 MPM/100ml is presented as a series of small maps at very small scale with no visible information about where and how the plume of effluent will move. Their modelling would enable them to show the lowest concentrations as the plume disperses but they’ve obviously decided they don’t want to show that information.

The Board should require Irish Water to release (mapped and raw) the data their model produces showing the dispersal of the effluent plume until it is no longer detectable. The obligation in the EIA process is to assess the impact on the environment, positive, neutral or negative and to supply all relevant information held.

When that analysis is made available then the public and the Board will have a much better understanding of the impact of the proposal.

  1. Location of the outfall

The modelling demonstrates that putting the outfall west of Ireland’s Eye would be significantly polluting. (Chapter 5 Consideration of Alternatives,https://www.gddapplication.ie/planning-sites/greater-dublin-drainage/docs/environmental-documents/volume-2a/Chapter%205%20Consideration%20of%20Alternatives.pdf)

However what Irish Water apparently haven’t considered is putting it further east. In public communications, they repeatedly described the location as 6km east of Portmarnock as if Ireland’s Eye and Howth didn’t exist at all. Irish Water are obliged to consider alternatives in a reasonable manner. In considering alternatives it is not sufficient to merely show that they could have picked a more polluting location for the outfall. To carry out a credible EIA, Irish Water need to demonstrate that the location they have picked is the optimal location and that, combined with the selected treatment methods, it will not lead to any reduction in water quality.

When an analysis of the alternative of locating the outfall further east is presented, the public and the Board will have a much better understanding of the impact of the proposal.

  1. Tertiary Treatment

The assessment of alternatives does not consider the use of tertiary treatment, in particular disinfection to reduce the risk of pathogens from the sewage effluent affecting water users or consumers of seafood from the vicinity of the outfall. Given that tertiary treatment is standard in many countries, it is very hard to understand why Irish Water haven’t considered it for this effluent. (It is referred to in relation to an alternative outfall further west but there’s no consideration of it for this outfall.)

When an analysis of the alternative of tertiary treatment, in particular disinfection, is presented, the public and the Board will have a much better understanding of the impact of the proposal.

  1. Overflows

At a public display associated with the development of the proposal I noticed some of the existing overflows from the sewage network discharging into surface waters were being retained. I specifically remember one which discharges into the Mayne River. I suggested at the time that any overflows whether from the new infrastructure or the existing nearby sewer infrastructure should discharge through the sea outfall.

I have searched through both maps and documents and I can’t find any specific information on overflows. Therefore I don’t know if existing overflows or any new ones are being diverted into the effluent outfall.

However, the Planning report contains the following general comment:

“The operational phase of the proposed Project, will reduce the extent of overflows from existing sewer networks to local water networks and courses, through the provision of additional waste water treatment capacity and diversion of a proportion of the wastewater loadings from a number of existing WwTPs into the new WwTP, and therefore improve the water quality of these.”

This is very important. Overflows from the sewer network are a major cause of pollution to our rivers and streams. They are the main cause of beaches being closed to swimming due to pollution in the Dublin area. Irish Water have been successfully prosecuted for some of these.

The public and the Board are entitled, not to a generalised assurance, but to specific information on which overflows will be reduced in frequency and extent and by how much. The inclusion of further measures to reduce overflows should be part of the consideration of alternatives. The Board should ensure that every reasonable opportunity to reduce the frequency and extent of overflows is being taken.

  1. Dredging Sediments

The Marine Biodiversity chapter of the EIA (https://www.gddapplication.ie/planning-sites/greater-dublin-drainage/docs/environmental-documents/volume-3a/Chapter%209%20Biodiversity%20(Marine).pdf) and the surveys done for it identify that the reefs at Ireland’s Eye are already being affected by the deposition of sediments and that the planned dredging will have a further negative impact on these protected reefs.

The consideration of alternatives does not include consideration of continuing the tunnelling along more of, or the entire length of, the outfall pipeline.

This appears to be contrary to the requirement the Habitats Directive.

  1. Water Framework Directive compliance

Much of the missing information identified above is required to determine whether the application is in compliance with the Water Framework Directive (WFD).

The Directive requires that water bodies which are not currently meeting good status be brought up to that level. The rivers and transitional waters in the affected sewage catchments are not at good status. Therefore the proposal must be assessed in terms of whether it is doing what it should to achieve the WFD obligations (e.g. in reducing overflows.)

The Directive also requires that water bodies at high quality be maintained at that status. The proposal must be assessed against this obligation. The information necessary to make this assessment must be provided and made available to the public for comment.

  1. Doldrum Bay

Irish Water continue to discharge a mixture of raw sewage and septic tank effluent into the sea at Doldrum Bay in Howth. Their EPA licence requires them to have ended this discharge by the end of 2011.

The maps they have supplied with this application are misleading in that they do not show the outfall (https://www.gddapplication.ie/planning-sites/greater-dublin-drainage/docs/environmental-documents/volume-5a/Figure%208.8%20Wastewater%20Treatment%20Plant%20Outfall%20Locations.pdf  )

and they do not show the sewer network catchment which leads to this outfall (https://www.gddapplication.ie/planning-sites/greater-dublin-drainage/docs/environmental-documents/volume-5a/Figure%203.3%20Potential%20Secondary%20Catchments.pdf.)

This lack of compliance with the law and misleading information in the application should be taken into account by the Board.

  1. Conclusions

There are major changes which should be made to the project to protect the environment and human health.

The application and EIAR lack many important pieces of information required to enable a proper assessment of the application, to comply with legislation on EIA, WFD and Natura 2000, and to ensure the most sustainable options are chosen.

I urge the Board to seek the necessary further information and ensure that the public is able to participate in considering it.

I enclose the €50 fee. Thank you for considering this submission.

Cost rental housing

Fingal County Council is planning to develop housing at Donabate. The Council has issued a “market sounding” document on etenders.gov.ie, which refers to a mixture of private houses for sale at market prices, “affordable” private houses to be sold at a discount to market rates, and social houses. I have asked them to look into developing cost rental housing and will follow up at the next Council meeting. My letter is below:

A chairde,

Thank you for sending on this paper. There is a housing approach which has been omitted from the sounding paper – provision of public housing on a cost rental basis.
The Oireachtas approved the attached motion on 6th March. The Minister for Housing Planning and Local Government said in April that cost rental was a “key part of the Government’s Housing Strategy”.
There are some significant advantages to making housing affordable by means of a cost rental system as opposed to by the provision of a discount on the sale of houses:
  • Cost rental provides secure affordable accommodation to the large segment of the population who do not qualify for social housing but are unable to secure a mortgage to buy.
  • Cost rental housing remains permanently affordable, unlike “affordable” housing which may only be affordable once, as it will in time be sold on at a market rent.
  • Because the costs of development are fully recovered the capital can be reused for further cost rental housing development.
  • Cost rental will facilitate social mix because HAP can be applied to make up the rent for lower income tenants.
  • In cities where it has been provided in quantity, cost rental has a moderating effect on rents.
This should be a key part, or indeed the dominant element, of the new housing development at Ballymastone. Can the practicalities be investigated either through, or in addition to, the market sounding?
Attachments:

Oireachtas Cost Rental Housing Motion 6th March 2018

“‘Cost rental’ scheme key part of housing strategy, says Minister” Sorcha Pollak, Irish Times -Apr 27  2018

“Cost_rental_housing:_a_model_for_Ireland”, Paul Goldrick-Kelly, NERI Research Institute, May 2018 

“Public_Housing_Provision:_Cost_rental_as_an_affordable_sustainable_solution”, Social Justice Ireland 12th March 2018

Ballymastone_Market_Sounding, document on etenders.gov.ie

Portmarnock to Baldoyle Greenway gets go-ahead

An Bord Pleanála has approved the Baldoyle to Portmarnock Greenway. Here’s the decision.

Provision of this important link for people walking and cycling in the Baldoyle and Portmarnock areas has been a priority for local residents and Councillors.  This is an important part of a wider network. The use of segregated routes to link the suburban towns in the area is an approach I hope will be followed. This is also an amenity route similar to the coastal promenade from Sutton to Sandycove and gives access to the new parkland between Baldoyle and Portmarnock.

I particular welcome the scaling down of the lighting proposed for the route, which I called for in my submission. It is very positive to see An Bord Pleanála take proper account of the impact on bats and on the visual character of the Green Belt by requiring that the lighting be by bollards rather than the 6m poles originally proposed.

Further info:

My submission to An Bord Pleanála

Wider context of work on Greenways in Fingal (Report to Planning and Strategic Infrastructure SPC 23rd July)

 

Fingal to work on improving cycling access to Howth/Malahide Secondary Schools

Following discussions with teachers in two of the local secondary schools, I proposed the following motion to the Area Committee last week:

“That the Council consults with students and teachers in the secondary schools in the Howth / Malahide Area in relation to the improvements needed in order to improve the safety of the access routes to the schools and in order to facilitate an increase in the numbers of students travelling to and from school by foot or by bicycle and a reduction in the numbers travelling to school by car.”

The motion was agreed at the meeting. I think there is a mixture of approaches needed, varying between schools. Two important aspects of this are the Green Schools Committees, one of whose targets for getting Green Flags is transport, and the potential to get students involved in solving the problems they experience cycling to school

Submission to Metrolink consultation

I have made the following submission to the public consultation on the proposed Metrolink.​

1. Prioritise walking and cycling.

​Walking and cycling are the highest priority modes in transport policy. Logically therefore, public transport infrastructure proposals should not only not obstruct or degrade walking and cycling routes, every opportunity they present to improve permeability, safety, convenience and attractiveness for walking and cycling should be taken.​ Any public transport proposal such as this one should also be a scheme to improve walking and cycling in areas being served and affected.

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Fingal trials vinegar and steam instead of weedkillers in Parks

Fingal County Council is reducing pesticide use, implementing policy changes sought by Grern Councillors. This includes both letting wild plants grow in some areas and trialling safer alternatives to conventional pesticides.

As reported to this month’s Council meeting, alternatives including steam and foam are being used to deal with weeds coming up in locations like paving cracks. Visitors to Malahide Demesne may notice the smell of vinegar which is being used as a substitute for the controversial weedkiller Glyphosate.

Commenting on the implementation of the new policy, Cllr. David Healy said: “Phasing out pesticides is vital to protect our insects, particularly the pollinating insects which have such an important role in ecosystems. Our parks and open spaces must be places where nature can thrive. Green thinking says ‘think globally, act locally’ and we are very glad that Fingal is putting this into practice.”

Cllr Roderic O’Gorman commented: “It is good to see Fingal responding to the public concerns at the use of toxic chemicals in public places. As Councillors we hear these concerns first-hand. When people visit their local parks and open spaces, they want to be confident that these are safe and healthy places, in which they can let their children play freely.”

The update given to Fingal County Council’s monthly meeting regarding the plan can be found at p47 of these minutes.

My submission which led to the change in policy (including some photos of non-use of herbicides elsewhere) is available here.

The All-Ireland Pollinator Plan is here.

Threat to Malahide Demesne resurfaces for a third time

Unfortunately, the threat to tarmac over some of the playing pitches at Bridgefield in Malahide Demesne has reappeared.

A report on parking in Malahide was brought to the March Area Committee. It seems to be intended to make the case for the conversion of some of the Bridgefield pitches to car parking.

The proposal to convert playing pitches to car park was originally made in 2009. The Council initiated a Part 8 process but abandoned it due to the strength of public opposition.

The proposal reappeared in late 2015, together with a proposed Forest Adventure Area. Despite the fact that the Law Agent advised that the relevant planning regulations hadn’t been complied with, a bare majority on the Council approved the proposal.  That proposal was abandoned in 2016 following a High Court challenge by local resident Noel Mahon.

I will continue to oppose any further conversion of parkland to car parking. We need to protect the Demesne for future generations, improving access by foot, bicycle and public transport.

This recurrent proposal is undermining public confidence in the management by the Council of the wonderful asset. In September I proposed that there should be some sort of formal or informal input from park users and the local community. The proposal didn’t get the necessary level of support but I think it is worth returning to.

 

Make your observation in relation to the Baldoyle to Portmarnock Greenway by Friday

Friday is the deadline for observations on the proposed greenway from Baldoyle to Portmarnock. Observations should be made to An Bord Pleanála in relation to application 300840. My submission strongly supports the route which has been one of my main goals as a Councillor. The changes I propose to the application are that a) the lighting needs to be minimal to protect both the wildlife and the landscape and b) the path structure and surface need to be designed and built to a high standard.

Baldoyle to Portmarnock Greenway is before An Bord Pleanála

Fingal County Council has applied to An Bord Pleanála for permission for a greenway between Baldoyle and Portmarnock. Details of the application are online here as well as in Baldoyle Library and the Council’s offices in Swords and Blanchardstown. Observations on the proposal can be made to An Bord Pleanála until 23rd March.

The cycling and walking route between Baldoyle and Portmarnock will provide for a high quality transport link and amenity route through the Green Belt between these towns. It responds to the demand from local residents for improved green transport opportunities along what is now a hostile stretch of road. It is part of the Bray to Balbriggan coastal greenway which the Green Party has been working for over many years.

 The application is for a high quality route with pedestrians and cyclists separated. This recognises the importance of the route for transport cyclists as well as its role as an amenity for the public walking along the nature conservation area at Baldoyle Estuary and the Mayne River.screen-shot-2018-02-07-at-8-13-34-pm

However, I am concerned about the proposal for 6m high lighting columns along the route. I will be proposing to An Bord Pleanála that these be replaced with low level lighting or path markings instead.