Ms Sinéad O'Brien:

First, I wish to make a few introductory remarks about the current state of our water and I will then present a synopsis of the six key issues SWAN has identified. A little like the Water Forum, we have a lot of issues, but we have just selected our top issues to present to the committee today.

Despite the impression of Ireland as clean and green globally, more than half of our rivers, lakes and estuaries are currently unhealthy. That means they are failing water framework directive status. Nitrate and phosphate pollution is at an unsatisfactory level and it has increased significantly since 2013, and we have lost a shocking 96% of our most pristine rivers in the past 30 years. In addition, more recently, an interim assessment of the previous river basin management plan reveals that only two out of ten expected outcomes of the plan have been achieved.

While SWAN very much commends the work of officials in the Department's water advisory unit, staff in the local authority waters programme and in the excellent EPA catchments unit, we believe all of this good work has been negated by conflicting policy in other areas, in particular a lack of investment and unsustainable land use, which is driving nutrients to levels that are unsustainable for the environment and to the detriment of Ireland and ultimately its people.

I will give committee members a quick flavour of our key issues, some of which are shared with the Water Forum. The first one is the lack of ambition and specific actions in the plan. Our overarching message to the committee today is that there is a lack of ambition in the plan and it falls far short of what is required. It lacks targeted actions to bring all of our water bodies up to good status, which is required by the water framework directive, and is not a coherent response to the directive. Neither is it in line with the programme for Government commitment on the directive. The continuing decline in water quality demonstrates that the current policy is not working. That leads to our first recommendation which is that the ambition of the plan must be in line with the directive and it must include a full set of targeted, specific measures necessary to bring every water body up to good status by 2027, as required by the directive. We must do that if we are to avoid the opprobrium of the EU and our own citizens.

The second issue to which we want to draw the committee's attention is water governance. Despite some new administrative structures that we might discuss later, water management remains fragmented and opaque and there is no central body or agency responsible for implementation of the previous or current plans. This was also highlighted by the Institute of Public Administration in a review last year. Our recommendation in this regard is that we need to establish an appropriately resourced river basin management plan project and management secretariat that is responsible for oversight, co-ordination and monitoring of the plan.

Our third recommendation on public participation is closely related to this. While we welcome the establishment of the national Water Forum, of which I am very happy to be a member, and the work of community water officers, in addition to the commitment to develop 46 catchment plans, the river basin management plan does not have a commitment that the public will be involved in their development. Volunteer-run catchment groups such as the Rivers Trust are not resourced in the way they need to be if they are to play the vital role envisaged for them by the State. We recommend that the public must be involved in the development of plans for the 46 catchments around the country and that they need to be resourced adequately to do that in order to secure effective public engagement. This needs to be facilitated by a team of 46 catchment water officers, as opposed to the 13 we have now.

As we all know, agriculture has the most significant impact on our waters, but since colleagues from An Taisce will be dealing specifically with that, I will not speak any more about it and I will move on to urban waste water. The draft plan is far too weak on the significant impact of urban waste discharges on the environment. This is the main source of pollution in 208 water bodies, yet the proposed plan does not set out measures to fix these by the deadline. We recommend that Irish Water's capital investment plan must include specific work and actions to address pollution in those 208 water bodies that are polluted by sewage. It must also set out transparently where this waste water pollution is happening; the waste water plant or system causing it; and where there is and, critically, where there is not - a plan of action to address this, with a timeline.

The second last issue to which I draw the attention of the committee is forestry. Again, there are no new measures in the plan, targeted or otherwise, to address the impact of forestry, despite the fact that it is causing pollution in 233 water bodies, including in many of the pristine water bodies we spoke of earlier. Instead, the plan relies on the roll-out and uptake of current initiatives such as the licensing system, with no link made to how that will restore degraded waters. The additional risk posed by increased national climate change targets for forestry is not addressed in the plan. We recommend that all forestry operations must be subject to a water framework directive-specific assessment, and they must contain site-specific stipulations for water protection, taking into account the cumulative impacts of multiple plantations in a catchment. We also need sensitivity mapping to identify the most vulnerable catchments, so that as forestry is rolled out in the coming years we ensure that only the right tree is planted in the right place.

The final point relates to physical modifications to our waters. This poses the second biggest pressure to inland waterways, with channelisation having the most impact due to the significant disturbance and damage to the ecology caused by in-stream dredging and clearance activities, including siltation, disturbance of spawning beds, changes in water quality and disconnecting rivers from their floodplains and wetlands. This is in clear contravention of the water framework directive, which mandated that we should have had regulations in place since 2012 for these activities. Therefore, we welcome the proposal in the plan that there will be new legislation and new water and planning guidelines.

With all due regard to community safety, this new legislation must include a WFD-specific assessment in advance of interventions such as dredging, drainage and flood protection. Projects must achieve WFD compliance and there must be an urgent assessment of catchment-scale soft options which maximise upstream attenuation, as part of sustainable flood management. We are also calling for a prohibition on wetland drainage and commitment to a national river and wetland restoration programme. I thank the members for their attention. We hope the committee may wish to play a role in securing a stronger and more ambitious plan that reverses pollution and ensures the security of clean and safe water for people, nature and the economy in these deeply uncertain times.