Mr. Barry Deane:

I introduce my colleague, Mr. Brian McDonald.

The National Federation of Group Water Schemes, NFGWS, thanks the joint committee for giving us the opportunity to attend. While the NFGWS welcomes the overall proposal, there are several aspects which are likely to present a significant challenge for the private group water schemes sector. The following is a summary our initial observations.

The requirement for a risk assessment approach to monitoring, from catchment to consumer, outlined in Articles 7 and 8, with particular emphasis on the source catchment, is recognised internationally as best practice in identifying risks that can potentially impact on drinking water supplies. The NFGWS is committed to this approach as the first step in protecting drinking water supplies and has been advancing work in this area on all regulated private supplies in recent years. However, the completion of detailed assessments and the implementation of associated measures to overcome identified risks on every scheme could pose a significant challenge in the short term. Any timeframe for the completion of assessments and the implementation of mitigating measures that might arise needs to be closely considered from a practical perspective. The group water schemes sector does not have the power of enforcement to implement significant measures to mitigate risk at catchment level and relies heavily on the good will of the community and the enforcement powers of the local authority to overcome significant issues.

On monitoring implications,the schedule of parameters to be monitored under the proposed directive sees the addition of several new parameters to the annexed list. The requirement to monitor water for new and emerging threats to water supplies is essential from a public health perspective. However, the scale and frequency of water quality monitoring proposed would see a significant increase in the current monitoring requirements. The proposal outlines significant increases in the level of compliance monitoring required, to a minimum of ten samples per annum for all small supplies of under 1,000 cu. m per day, and 52 samples per annum for supplies greater than 1,000 cu. m per day. In addition, all suppliers are required to monitor all parameters initially, even if there is a exceptionally low risk of occurrence, until sufficient evidence is obtained to justify ruling them out. By their nature, group water schemes are low-cost, community-owned, community-run co-operatives which would not have the capacity to carry out the increased level of quite expensive monitoring. We looked to get an indication of the costs that would be involved for a private, accredited laboratory to carry out this testing. We are looking at in the region of €1,857 to test for all parameters. For a group water scheme serving 30 houses, the cost over a 12-month period would be €18,570, or about €619 per house, which is quite significant. From our initial research, all of the proposed new parameters cannot be analysed in this country. For microplastics, we were unable to get a quote.

It appears that some parametric values in the Commission’s proposal differ from those recommended by the WHO. It will be difficult for individuals in group water schemes to understand and accept the need for such a change. The WHO produces international norms for water quality and human health in the form of guidelines that are used as the basis for regulation and standard setting worldwide. The proposal to introduce lower parametric values for certain parameters may also have practical and financial implications for the level of treatment required for certain water supplies.

On the practical implications for the group water schemes sector,under the proposed directive, responsibility for carrying out monitoring is placed on the water provider. In Ireland compliance monitoring of the private group water schemes sector is carried out by the water services authority which for group water schemes is the local authority, with only operational monitoring being carried out by schemes. Extensive guidance training for group water schemes will be required to fulfil this obligation. All monitoring results must also be published online, which, again, will provide a challenge for small schemes.Article 10 relates to the assessment of domestic distribution systems and monitoring for lead and legionella. Group water schemes are not technically competent to complete such assessments. Access and property rights would need to be considered to fulfil this role, as well as funding to implement measures to deal with issues identified.

The group water schemes sector's overall compliance with drinking water regulations has improved in recent years, with over 96% microbiological compliance in 2016. With the proposed changes to parametric values and the inclusion of new parameters, there will be a period of uncertainty about future compliance levels until further analysis is completed.

These are just some initial observations. The NFGWS will continue to review the proposal in the coming weeks to establish all potential implications for the group water schemes sector. It would welcome an extensive consultation process for this proposal prior to its implementation.