An Taisce welcomes the opportunity to comment on this public consultation. However, at the outset we would indicate that we have significant concerns about the adequacy of the analysis and data underpinning these proposed designations, and we are of the view that this designation process should not proceed.

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It is our view that the Department have manifestly failed to adequately carry out any of the designation tests which this documentation purports to provide. It is wholly inadequate from a public participation perspective, and the lack of analysis and data to underpin the answers provided for each of the designation tests is entirely inadequate to fulfil the requirements of Article 4(3). It is our firm view, that to proceed with any HMWB designation based on the documentation and analysis provided would be to infringe on the meaning and proper legal interpretation of the Water Framework Directive.

We would recommend a significantly improved designation decision process, based on appropriate analysis and data for each step which should be presented, justified and integrated into the consultation on the next River Basin Management Plan. This should involve waterbody-by-waterbody analysis and data, with a clear and transparent rationale, and an analysis of trade-offs.