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Submission extract:

An Taisce fully recognises the importance of ensuring a reliable and clean source of drinking water for the Eastern and Midlands Region, including the Greater Dublin Area, to meet supply challenges in the years ahead. We also recognise that the subject proposal appears to be the only significant plan to address those challenges.

We consider that any project introducing a major new drinking water source cannot occur in isolation, however. Water is a very finite resource and will only become more so as climate change worsens. We therefore welcome the progress made by Uisce Éireann on addressing the long-standing issue of water leakage in the existing water infrastructure, and recommend that leak reduction efforts in the Eastern and Midlands Region be increased even further so that, should the subject proposal be granted, water piped from the Shannon is not wasted. Similarly, we also recommend that demand reduction measures and programmes also be continued and expanded, including the promotion of water use efficiency measures, the incentivisation of conservation efforts among water users, the use of tariffs to promote conservation, and the use of water recycling and rainwater harvesting measures.

It is also crucial that any project to increase water supply will not have significant adverse environmental effects. An Taisce has multiple concerns in this regard, including about the adequacy of the assessments accompanying the subject application, which we discuss in the following sections.

Baseline

We would observe that the proposed abstraction is not being introduced into an ecologically neutral baseline. It is being proposed for an already significantly altered hydrological regime in which approximately 90–95% of the long-term average flow of the Lower River Shannon SAC at Parteen Regulating Weir is being abstracted from the SAC and diverted to Ardnacrusha hydroelectricity scheme. This leaves a predominantly uniform statutory compensation flow of 10 cumecs (m3/s) for 15 km of the old Lower River Shannon SAC channel, for the majority of the year.

The NIS and EIAR assess the proposed abstraction relative to this managed regime, without recognition that the baseline itself is both heavily hydrologically impacted and as a result ecologically constrained. The NIS and EIAR rely on modelling which depends on the statutory 10 m³/s compensation flow, with the implicit assumption that this is ecologically sound. However, this extant reduced flow condition has never been assessed against Water Framework Directive (WFD) objectives, or the conservation requirements of the SAC. As such, any project which depends on the hydrological status quo in order to operate is, in effect, relying on the continuation of the existing ecological degradation.

While the environmental assessments do demonstrate limited hydrometric change within the system, the assessment does not assess the adequacy of that system, or how it complies with our European environmental law obligations. The assessments have failed to demonstrate that the current compensation regime maintains the hydrological conditions consistent with WFD requirements in the >15 km SAC river channel between Parteen Regulating Weir and the confluence with the tailrace, or conducive to the conservation objectives of the qualifying interests of that SAC.

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