An Taisce welcomed the opportunity to comment on the Public Consultation on Ireland’s interim review of the Fifth Nitrates Action Programme, and the submission from An Taisce can be downloaded here.

Having reviewed all of the documentation provided for this review, we would highlight, in the strongest possible terms, that the evidence base provided to explain what benefit the additional measures will have for water quality is almost entirely absent. Indeed, we noted that the Natura Impact Statement (NIS) has very clearly highlighted the same.

Given that water quality has been declining for over a decade, it is unreasonable for the Department to expect the public to give them the benefit of the doubt. The very purpose of this review is to strengthen the measures provided for the protection of water quality, and the one thing this documentation does not provide, is an estimate of how much water quality will benefit from these proposed measures, or indeed evidence that the measures will work at all. Without an evidence base and rationale provided for why these measures are being proposed, this cannot be considered to be a meaningful public consultation.

In the midst of a water pollution crisis, on an issue which the public have repeatedly demonstrated was their primary environmental concern, this interim review does little to assuage the ever-growing public concern about Irish water quality and the impact of agriculture.