Submission to Irish Water and Response

Submission to Irish Water-August 2014

I along with Independent Councillors Joe Newman, Tony Murphy and Anne Devitt recently made a submission to Irish Water as part of the public consultation process.

Attached above is our full submission and below is a response from Irish Water.

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Irish Water acknowledges the fact that the Irish people have been investing in Ireland’s water supply through general taxation. It costs €1.2 billion every year to run the public water system, with €1 billion of this funding coming from the Exchequer. Irish Water has been set up by the Irish Government as this current funding model is no longer sustainable. In addition our infrastructure is badly in need of an overhaul. Despite the good work of the Local Authorities, lack of investment has given rise to weaknesses in the water system infrastructure resulting in high leakage rates, varying quality standards and disruptions to supply. The new funding model, based on revenue collection and reinvestment, will ensure the public water system can meet the challenges of the future and deliver a higher standard of water supply and wastewater treatment.

As part of the Draft Water Services Strategic Plan, Irish Water will look at international best practice and your feedback on this particular issue will be taken forward in writing the Draft WSSP.

In relation to future investment in the Fingal area, Irish Water published its Proposed Capital Investment Plan for 2014 to 2016 on 13th May. As part of this Proposed Plan, investment is prioritised where it can deliver the most urgently needed improvements in drinking water quality, leakage, water availability, wastewater compliance, efficiencies and customer service.  It is proposed to deliver/progress over 380 projects under the Plan which has been submitted to the Commission for Energy Regulation (CER) for consideration. Irish Water estimates that €1.77 billion will be required to deliver on the objectives of the 2014-2016 Capital Investment Plan (CIP). The CIP includes a number of both water and wastewater schemes in the Fingal area.

The Proposed Capital Investment Plan 2014-2016 and the supplementary Appendix 1 to the CIP is also available on the Irish Water website at http://www.water.ie/news/proposed-capital-investme/

Household Allowance

The Commission for Energy Regulation (CER) is responsible for determining the tariff for water under a series of public consultations. The public consultation on water charges has now been launched by the CER and Irish Water would encourage everyone to participate. Details of the public consultation, including how to make a submission are available on the CER website at www.cer.ie

Apartment Households

Irish Water is currently implementing Phase 1 of the National Metering Programme whereby water meters are being installed outside domestic residences on publically-accessible land at the location of the existing stop valve. The meters are being installed in line with the survey results as carried out by each Local Authority, and as legislated under the Water Services Acts.  Shared services do not come within the remit of this phase of the metering programme and if a shared service is identified no meter will be installed. Irish Water is gathering data on these types of services, and developing a strategy related to a potential second phase of metering.  This phase will look into any obstacles to metering of multi-unit developments in further detail.

Households that are connected to the public water and wastewater system who will not have a meter installed before the commencement of billing will be charged an assessed tariff. It is the intention that the assessed tariff will be designed to closely mirror the metered charge, and the CER and the Government are looking at other measures to ensure equity across the tariffs.

Customer expectations

Irish Water acknowledges your submission in this regard and will take the recommendation that more detailed concrete proposals in developing the Draft WSSP, on which a further public consultation will be held later in 2014 (details to be announced later this year).

In relation to the customer charter charge, this is determined by the Commission for Energy Regulation and Irish Water would encourage you to submit this to the CER as part of their public consultation process.

How Irish Water should ensure a safe and reliable water supply

Irish Water was set up under the Water Service Acts 2013 by Irish Government. The timelines for the commencement for water charges was therefore determined through a Memorandum of Understanding with the Irish Government and the Troika and was independent of Irish Water. The rebates for those where the water is not suitable for human consumption will be determined by the CER.

In relation to hard water, Irish Water monitors the drinking water quality for public supplies in accordance with the European Communities (Drinking Water) (No.2) Regulations 2007 and SI No. 122 of 2014 – EU (Drinking Water) Regulations 2014. These regulations specify that water authorities are to provide ‘wholesome and clean water that meets the requirements of the regulations’. In addition, the Environmental Protection Agency (EPA) is the water quality regulator and is the supervisory authority for public supplies under these Regulations. Irish Water is focused on providing a safe and secure drinking water supply to consumers.  Our objective is to ensure effective barriers to microbiological contamination and effective operation of the treatment processes.

The issue of hard water is a separate matter related to the mineral content (particularly calcium carbonate derived from limestone catchments).  There is no reference to, or limits for, hardness in the EC Drinking Water Directive or in the EC (Drinking Water) (No.2) Regulations 2007.  It will not be possible for Irish Water to provide general softening of waters for public supply as this would be cost prohibitive for the customer.

In relation to the issue of lead, all lead pipes in the mains distribution network in Ireland have been replaced. However, lead piping does exist on some private properties. It is the responsibility of the householder to replace the lead pipes from a point 225mm from where the Service Connection enters the boundary to the last lead fitting within the private property. The cost of this is the responsibility of the householder. If a home has been modernised since 1970 and all the pipe work has been replaced between the stop valve outside the home and the kitchen tap, there should be no lead in the property. If the home was built before 1970, it may have lead pipes. However, the presence of lead pipes does not necessarily mean there is lead in the water. The dissolving of lead into water is known as plumbosolvency. As the national utility Irish water can do a number of things to minimise plumbosolvency. This includes ensuring that the water leaving our treatment plants is at the correct pH to minimise the risk of lead dissolving into the water when it enters service pipes on customers’ property.

It is intended that the Draft WSSP will also address future population and housing increase and the supply of water and wastewater to meet these needs.

In relation to leaks, Irish Water is proposing to spend €150 million to accelerate leakage reduction and is moving to a much more proactive approach on leakage, with the long-term objective of reducing public and customer side leakage nationally by 50%. A First Fix Scheme is also being developed and details of this will be announced in due course.

How Irish Water should provide for the effective management of wastewater

The overall Irish Water strategy for wastewater treatment will be included in the Draft WSSP. The Capital Investment Plans will then include the specific details on projects and the costs for these. Irish Water has submitted the Proposed Capital Investment Plan for 2014-2016 to the CER for consideration.

New technologies and international best practice in the water services industry, as well as other utilities are being examined by Irish Water and will your submission in this regard is much appreciated.

Protection of the environment

Irish Water is regulated both economically and environmentally. The Environment Protection Agency (EPA) is the environmental regulator for Irish Water. Irish Water implements all relevant legislation in order to ensure the environment is protected including adhering to Strategic Environmental Assessments, Environmental Impact Assessments, the Water Framework Directive, and the Urban Wastewater Treatment Directive etc. Further details will be included in the Draft WSSP.

How Irish Water can support social and economic growth

This will be taken forward in the Draft WSSP.

Investing in our future

Asset Management is well established across the world as offering the basis for the most cost effective service delivery. The goal of Asset Management is to provide all customers with an equivalent level of service at least cost. This implies spending less money to achieve more, maintaining a stewardship of assets in the desired state, investing across whole systems with a whole life perspective. Your submission on this will be taken forward in developing the Draft WSSP.