Mr. Darragh Page:

I am grateful for the opportunity to contribute. I am joined by Ms Aoife Loughnane, a senior inspector with the drinking water team. I am the programme manager for the office of environmental enforcement. The EPA welcomes the Commission proposal to review the directive in light of scientific and technical developments that have occurred since 1998. In particular, the EPA supports the risk-based approach to the management of drinking water supplies using the water safety plan approach, which the agency has long promoted. The EPA has assisted the Department of Housing, Planning and Local Government on the drinking water expert group established under the existing drinking water directive and has been active in the various consultation phases prior to the publication of the recast directive.

The draft proposal represents a significant change compared to the existing directive and I will outline two of the main scientific and technical changes that will impact on Ireland.

The first is the change to drinking water standards. The World Health Organization carried out a review on behalf of the Commission of the existing standards in order to identify new potential standards. While the Commission had regard to the review, it did not adopt the recommendations of the WHO, a fact that it has been keen to stress. The proposal includes the introduction of standards for ten new chemical parameters, namely, beta-estradiol, bisphenol A, chlorate, chlorite, haloacetic acids, microcystin-LR, nonlyphenol, PFAS (individual), PFAS (total) and uranium. With the exception of uranium, very little historical monitoring has been carried out in Ireland within these parameters. The Commission has chosen to adopt the existing WHO guideline values for the parameters mentioned, with the exception of chlorate and chlorite. The adoption of a more stringent standard for chlorate would have significant consequences as it would greatly restrict the use of sodium hypochlorite as a disinfectant. If the less stringent WHO guideline value was applied, this would not be an issue.

The Commission has also decided to retain the standards for some parameters such as nickel, boron, selenium and antimony, contrary to the advice of the WHO which had recommended revising the standards upwards. The draft proposal also proposes to reduce the lead standard to 5 g/l from 10 g/l. As was outlined by Irish Water, this standard cannot be complied with without the full removal of all lead from the public water supply network and private and commercial plumbing systems.

A further significant change to the directive is that all exceedances of the standards must be considered to be a potential danger to human health. Currently, each exceedance is assessed in consultation with the HSE and a decision made as to whether there is a risk. This will be particularly problematic for those parameters where the Commission has opted to impose a standard that is more stringent than the WHO guideline value.

The second area in which there have been significant changes is monitoring. The draft proposal proposes a significant increase in monitoring frequencies and changes to those parameters that have to be monitored. The directive does permit a reduction in monitoring frequency for some of the parameters but only after a minimum of three years' monitoring has been carried out. For example, a supply for 4,000 people, or around 800 cu. m, is currently required to be monitored five times a year, or four times for a small group of parameters and once for the full suite. This will now need to be monitored ten times for the full suites of parameters irrespective. I have included a table in the document which I do not propose to go through, giving an outline of the main implications. It will result in significantly increased monitoring by Irish Water and of private water supplies.