Dr. Kieran Craven:

Further to what Ms O'Brien said, we do not contend that abstraction is an issue at a national level. It really is at the local level. The EPA believes that 20% of water abstractions are less than 25 cu. m per day, which means they are unknown. Abstraction can have a very large impact at a local scale depending on the interaction of the available water, whether it is groundwater in connectivity with surface water, whether there are adjacent wetlands and whether there are domestic wells there. The local impact of that abstraction can be profound.

I believe the EPA's 6% figure is based on a database that has been in existence with various iterations since about 2005. It has tried to accumulate data on the main abstractions. Between 2005 and 2017 a number of points were raised about the omissions from that database. About 10% of water schemes were omitted. Ones from industry and agriculture and unregulated ones are omitted. The total amount of abstractions and specifically the locations of the abstractions are still relatively unknown. Using an incomplete database will lead to an underestimate of the impacts. We contend that on a local scale much is unknown about the impacts of abstractions.

When we take into account the expected effects of climate change, which based on reports by the EPA predict up to a 20% reduction in summer rainfall, increases in dry periods during the summer when we might expect certain industries such as agriculture would then have a higher demand for water and changes to precipitation levels as well, it all exacerbates the requirements for water, increasing the stresses on water, particularly on a local to regional scale. We feel the proposed legislation should protect and be able to respond to these things. Having thresholds of 10 cu. m for registration and 20 cu. m for licensing will increase that understanding of abstractions. Particularly at the local scale, we will be able to respond to that to preserve the vulnerable and at-risk water bodies.