National Inspection Plan 2018-2021 Domestic Waste Water Treatment Systems Public Consultation Response Document
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National Inspection Plan 2018-2021 Domestic Waste Water Treatment
Systems
Public Consultation Response Document
The EPA published the National Inspection Plan 2018 – 2021 Draft For Consultation on the 15th of
December 2017. The public were invited to submit comments on the draft consultation document by
the 26th of January 2018.
The EPA received nineteen submissions. Seventeen of the submissions were from organisations and
two submissions were from individuals in a private capacity (see Table below).
List of Submittors
Chartered Institution of Water and Environmental Management (CIWEM)
Donegal County Council
Wicklow County Council
Leitrim County Council
HSE National Drinking Water Group
HSE Environmental Health Service
Irish Rural Link
Cork County Council
Fingal County Council
Irish Farmers Association (IFA)
Irish Onsite Wastewater Association (IOWA)
Kerry County Council
Mayo County Council
National Federation of Group Water Schemes (NFGWS)
Sustainable Water Network (SWAN)
An Foram Uisce
FH Wetland Systems Ltd.
Two individual submissions.
Table 1: List of Submittors
The continued two strand approach of inspection and engagement was broadly welcomed. The
greater emphasis on engagement was positively received. The revised risk based methodology was
considered to represent a more focused approach. Reference was also made to the EPA’s online
domestic waste water application (DWWA) which it was stated makes the recording and reporting of
data by local authorities and the EPA much easier.
Each submission was reviewed. The comments received have been grouped together and categorised
under a number of subject headings. The EPA’s response is presented under each of the subject
headings in the following sections. Where edits have been made to the final NIP, in response to the
submissions received, these have been outlined.
1RISK ASSESSMENT METHODOLOGY
Issued Raised:
Positive feedback was received in relation to the revised risk based methodology and the more
focused approach for inspections was welcomed.
A clarification was requested on the degree to which it is intended that the proposed NIP will be
revised in light of ongoing inspection findings and Water Framework Directive (WFD) characterisation.
While a risk based methodology was supported in principle, measures were requested to ensure all
domestic waste water treatment systems (DWWTS) currently posing a risk to the water environment
be detected and fixed by 2021.
Some clarifications were requested in relation to the risk based methodology and why waterbodies
that are designated as being at risk and for which DWWTS have been identified as a significant
pressure (Category 3) are designated a lower priority for DWWTS inspections than at risk waterbodies
in Areas for Action (Category 1 and 2). Further information was requested on how catchments of High
Status Waters, Bathing Waters, Shellfish Waters and Freshwater Pearl Mussel Waters have been
considered.
Clarification was requested in terms of the risk assessment methodology and the Blue Dot
programme which states that a proportion of inspections should be focussed on high status
catchments.
A concern was raised in relation to some areas of the country where significant numbers of dwellings
rely on DWWTS in areas which are categorised as “Not At Risk” but groundwater supplies in these
areas are at risk.
Response:
The revised risk assessment methodology as put forward in the final NIP will remain in place for the
four year period 2018 to 2021 to tie in with the 2nd cycle of the River Basin Management Plan (RBMP).
The next review will tie in with the preparation of the 3rd cycle RBMP.
The revised risk based methodology has followed an evidence based approach building on the work
undertaken as part of the WFD characterisation process. This revised methodology is aimed at helping
to meet the environmental objectives of the WFD. The risk-based inspection process is one part of a
two-strand approach to meeting the WFD objective: the second strand is focussed on engagement
strategies.
The revised risk based methodology has been aligned with the 2nd Cycle RBMP by prioritising
inspections in those water bodies that have been identified as RBMP priorities. These include areas
for action where water quality improvement can be achieved during the 2nd cycle of the RBMP, high
status objective water bodies, water bodies in protected areas and those water bodies that have
2deteriorated since the 1st Cycle RBMPs. These water bodies have been included under NIP Category 1
and 2 if they have been identified as being at risk.
The following additional text has also been inserted in Section 2.3 of the final NIP.
“It should be noted that the RBMP priorities in the NIP include areas for action prioritised for further
work in the 2nd cycle and At Risk waterbodies in the areas for action are included in Category 1 and 2.
Where High Status Waters and deteriorated waterbodies have been identified as being At Risk and
water bodies in Protected Areas, (for example Bathing Water, Shellfish Waters and Freshwater Pearl
Mussel Waters) have been identified as not meeting their protected area objectives, these are also
covered under the RBMP priorities in Category 1 and 2.”
In response to the issue in relation to a Category 3 waterbody being assigned a lower rating than
Categories 1 and 2. It should be noted that while Category 3 includes areas where DWWTS have been
identified as a significant pressure these areas do not fall within Areas for Action or RBMP Priorities.
The aim of the updated risk based methodology is to tie in with the aims of the RBMP by focusing a
higher proportion of inspections within the Areas for Action and RBMP Priority water bodies. Areas
for Action are where action has been prioritised for the second cycle of the RBMP and where there is
the greatest potential for contributing to water quality improvements.
The significant pressure analysis that has been carried out to date has been on the basis of a desk top
assessment at the water body scale using available datasets and models, and engagement and
discussion of these water bodies with all local authorities and public bodies with a water remit. Once
the investigative assessments commence in the Areas for Action and more detailed water body
information becomes available additional significant pressures may become apparent. A separate
resource, not included in the NIP, will be available to follow up with householders where additional
DWWTS are identified as a significant pressures in order to achieve water quality improvements.
It should be noted that the methodology takes in to account the potential risk to groundwater
supplies as per the map layer ‘Potential risk to groundwater supplies from DWWTS’. These areas have
been categorised as having increased potential risk to groundwater supplies and have been included
in the overall risk zone classification.
The purpose of the inspection plan is to check on the operation and maintenance of the DWWTS
rather than to determine the effect of a DWWTS on the groundwater quality. A properly designed,
suitability sited, correctly operated and maintained DWWTS will not be expected to be adversely
impacting on the groundwater quality. The inspection process will identify any remedial measures
required thereby reducing the potential impact on groundwater quality.
3Table 2.2 of the final NIP has been amended to include the full text for the category description to
provide clarity. The edited text in Table 2.2 is in italics.
Waterbody Category Description Risk Zone National Number of
category number of inspections
inspections per 1,000 km2
per of each water
waterbody body category
category
Category 1 Plan Priorities (Areas for Action 1A & 1B 302 150.8
and RBMP priorities) “At Risk
Water Bodies” where DWWTS
have been identified as a
significant pressure
Category 2 Plan Priorities (Areas for Action 2A & 2B 502 35.1
and RBMP priorities) “At Risk
Water Bodies” where DWWTS
have not been identified as a
significant pressure
Category 3 “At Risk Water Bodies “that are 3A & 3B 30 27.8
not an Area for Action or RBMP
Priority where DWWTS have been
identified as a significant pressure
Category 4 Remaining “At Risk Water Bodies” 4A & 4B 107 14.2
where DWWTS have not been
identified as a significant pressure
Category 5 “Not at Risk” and “Review” 5A & 5B 59 1.4
Waterbodies
Table 2.2 Density of inspections per water body category
UNREGISTERED SITES
Issues Raised:
The benefit of targeting inspections on unregistered DWWTS was questioned. Several local
authorities commented that it was very difficult to identify unregistered sites. The separation of the
inspection process from the registration process was suggested.
Response:
The EPA has reviewed the comments received in relation to the difficulties experienced in identifying
unregistered sites. It is considered that because of the low % of unregistered properties nationally
(5%) that it can be challenging to identify unregistered properties in a particular risk category.
4Local authority inspectors should continue to record whether a site is registered or not as part of the
inspection process and continue to inform home owners of their obligations to register their DWWTS
in accordance with the Water Services Act 2007 as amended by the Water Services (Amendment) Act
2012 during the inspection process.
Section 3.3 of the NIP has been amended to include the following text “If possible, priority should be
given to the selection of unregistered properties for inspection in the first instance. However it is noted
that the registration rate nationally is 95% and therefore it may not always be possible to target
unregistered properties”.
In addition Figure 3.1 of the NIP has been amended: “When choosing sites to inspect, priority should
be given to unregistered sites, if possible”.
INSPECTION NUMBERS
Issues Raised:
Concerns were raised that the proposed minimum of 1,000 inspections per annum on a national basis
is too low and is not sufficient to achieve the objective of protecting human health and water quality
or raising awareness. It was recommended that the inspection numbers should be significantly
increased as a matter of priority.
Response:
It is proposed that the minimum number of inspections will remain unchanged at 1,000 per annum. In
addition local authority inspectors also carry out verification inspections of DWWTS annually and
inspections in response to complaints.
The characterisation process for the draft river basin management plan identified that 11% of the at
risk water bodies are being impacted by DWWTS. This is lower than other sources such as agricultural
activities (64%) and urban waste water discharges (22%). The RMCEI figures for 2016 indicate a total
of 25,868 water and waste water (routine and non routine) planned inspections for 2016. The 2016
figures included 2,511 farm inspections (9.7%) composed of 1,492 under GAP regulation and 1,019
under other farm inspections. The number of inspections for discharge licences to waters was 1,865
(7.2%).
The minimum 1,000 inspections of DWWTS under the NIP represents 3.9% of planned inspections and
this is considered appropriate when compared to the number of planned agricultural and waste water
based inspections.
Additional inspections may be carried out by an individual local authority if there is evidence at a local
level that DWWTS are causing an issue in particular catchments. The minimum number of inspections
required to be undertaken during each year of the plan have been specified per local authority area.
5Section 3.2 of the NIP has been amended to include the following: “Investigative assessments will also
be taking place as part of the RBMP. These investigative assessments are separate to the NIP for
DWWTS”.
INFORMATION ON INSPECTION PROCESS FOR HOME OWNERS
Issues Raised:
Requests were received for the inclusion of information on what is involved in an inspection to assist
home owners.
Response:
Section 3.5 of the NIP has been updated to provide information for home owners on what is involved
in an inspection. The following text has been inserted in the NIP.
“A pre-inspection letter is sent to a home owner 10 days in advance of an inspection taking place. A
local authority inspector will check that the treatment system is fit for purpose and is not giving rise to
a risk to public health or the environment.
The home owner will be notified of the findings within 21 days of the inspection. If the system is
deemed to pose a risk to public health or the environment the local authority will issue an advisory
notice directing the owner to remedy the matters specified in the notice by a specified date.
Additional information on what is involved in an inspection is available on the EPA website at
http://www.epa.ie/water/wastewater/info
Information is also available on the “What to expect from a septic tank inspection” leaflet which is
available for download at the following link http://www.housing.gov.ie/sites/default/files/migrated-
files/en/Publications/Environment/Water/FileDownLoad%2C33590%2Cen.pdf
There is also a video available outlining what to expect from an inspection at the following link
http://www.epa.ie/water/wastewater/guidance/whattoexpectfromaninspection/”
INSPECTION PROCESS
Issues Raised:
Positive feedback was received in relation to the EPA’s online domestic waste water application
(DWWA). It was considered that the system makes the recording and reporting of data by local
authorities and the EPA much easier.
The mandatory inspection and upgrading of treatment systems in conjunction with home extensions,
the sale of property and the option to undergo a voluntary inspection was suggested.
6It was suggested that home owners should be informed that their systems do not comply with the
current Code of Practice Wastewater Treatment and Disposal Systems Serving Single Houses during
the inspection process including cases where advisory notice will not be issued.
The option of inspections being undertaken by the private sector was suggested.
It was recommended that sites should be selected in a consistent manner.
It was noted that coordination would be required in relation to the inspections being carried out by
the shared-resource within the recommended areas for action under the RBMP and the inspection
work which local authority staff will be carrying out under the National Inspection Plan. It was
recommended that opportunities and synergies between the NIP Programme and the Blue Dot
Programme could be explored.
It was recommended that the EPA consider constructed wetlands, motorway service areas,
commercial and industrial on site treatment systems as further potential inspection sites under the
NIP.
It was suggested that the online Domestic Waste Water Application (DWWA) on EDEN should be
developed and rolled out in more areas such as Farm Inspections, Section 4 Licence Inspections and
Catchment Investigations for the recording and retention of data.
Response:
Mandatory inspections and upgrading of DWWTS in conjunction with home extensions or property
sales and voluntary inspections of DWWTS do not form part of the risk based methodology.
Allowing individuals to request inspections is considered counterproductive to the consistent
application of the risk based methodology.
The purpose of the inspection regime is to demonstrate compliance with the Water Services Act 2007
as amended by the Water Services (Amendment) Act 2012 and to protect human health and water
quality from the risks posed by the DWWTS.
All local authorities should document their site selection methodology and retain copies for possible
future auditing by the EPA. Guidance has been prepared by the local authority site selection and
inspection working group including a local site selection plan template to ensure sites are selected in
a consistent manner. This is available through the Septic Tank Inspectors Network on NIECE.
The coordination of activities between the local authorities and the new shared resources is outside
of the scope of the NIP. It is anticipated that workshops will be held to discuss the coordination of
these activities.
In response to the query on the Blue Dot programme local authorities will carry out the inspections as
per the NIP. This means that some inspections will be carried out in the Areas for Action. The WFD
3B Investigative Team will not be doing inspections under the NIP however if they find problems
7arising from DWWTS they will be able to speak to the home owners and point them towards any
grant schemes which are available.
Under the legislation the scope of the NIP is limited to DWWTS. At present the EPA has no plans to
expand the online application to other local authority inspection areas.
REGISTRATION SYSTEM
Issues Raised:
More proactive enforcement of the registration system was suggested and measures should be put in
place to get the remainder of septic tanks registered.
A comment was received in relation to home owners who have bought or inherited properties with
un-registered DWWTS. They are currently excluded from availing of grant support where the system
is inspected under the NIP process. It was recommended that the legislation dealing with the grant
system should be amended to address this anomaly.
Response:
The registration process is outlined in legislation. The national registration rate is very high at 95%.
Enforcement of the registration system is outside of the scope of the National Inspection Plan. The
EPA has forwarded comments in relation to the registration system and grants to the DHPLG.
ENGAGEMENT PROCESS
Issues Raised:
A large volume of comments were received in relation to the engagement process. The greater detail
provided in terms of the engagement activities was welcomed. The following suggestions in relation
to the engagement process were put forward:
National targeted media campaign using all forms of social media;
Engagement with home owners before and after inspections;
Engagement with home owners with unregistered systems;
Engagement via information evenings;
National strategy and implementation plan led by EPA;
Engagement with site assessors;
Targeted awareness campaign with NFGWS following from the community led DWWTS
education and desludging initiative;
Expand role of LAWCO to include engagement at national and local level to facilitate
community education and awareness;
Increase home owners awareness of legal obligation to maintain system on regular basis;
More readily available information for home owner;
NIP report to include more practical information for general public;
Highlight impact of malfunctioning DWWTS on nearby private wells etc.
8Response:
The proposed engagement activities for the 2018 to 2021 reporting period are outlined in Table 4.2 of
the NIP. The suggestions received during the consultation period will be considered by the
engagement working group for incorporation into the engagement strategy.
In response to the comments received during the consultation period the following text will be
inserted in Section 4.3 Proposed engagement activities 2018 – 2021 in the NIP.
“As part of the consultation process the public were invited to provide suggestions on ways to engage
with home owners to increase awareness around issues relating to the operation and maintenance of
DWWTS.
In response to the submissions received during the consultation period it is proposed that the following
will be reviewed by the engagement working group to establish a programme for roll out during the
lifetime of the 2018 to 2021 NIP.
National media campaign.
Development of implementation plan on citizen engagement activities.
Targeted awareness campaign with groups such as NFGWS or LAWCO via local information
evenings.
The EPA will continue to assist with the provision of information leaflets on DWWTS and
private wells to local authorities. These leaflets have been developed by the engagement
working group. Local authority inspectors will be required to continue to engage with
householders during the inspection process and distribute the information leaflets on both
DWWTS and private wells. A link to the leaflet “Have you checked your well water supply?” is
provided here http://www.epa.ie/pubs/advice/drinkingwater/SS%20Wells%20Web.pdf.
Further work to take place on the feasibility of the expansion of bundled service contracts for
desludging.
The agreement of metrics to ensure that progress with engagement can be measured during
the implementation of the 2018 – 2021 NIP.
9SLUDGE MANAGEMENT
Issues Raised:
The issues raised in relation to sludge disposal included: the 50% volume deficit in the current urban
wastewater treatment infrastructure to treat sludge from DWWTS; difficulties in accessing
information on permitted waste contractors for desludging; the variation in the cost of sludge
collection and disposal and lack of awareness of the restrictions on sludge spreading in relation to
quality assurance schemes for food production.
It was suggested that the final recommendations from the NFGWS “GWS-led community DWWTS
educations and desludging initiative” be considered as part of the final National Inspection Plan 2018
– 2021.
Response:
The following comment has been inserted in Section 5.1 of the NIP, in relation to the national strategy
for waste water sludge. “The Agency is committed to continued liaison with both the Department of
Housing, Planning and Local Government and Irish Water on this issue”.
Information on permitted contractors is available on the National Waste Collection Permit Office
website (https://www.nwcpo.ie/). Section 4.2 of the Final NIP has been amended to include the
following: “Local authorities should also maintain a list of permitted contactors in their area on their
website and provide a list of permitted contractors to home owners as part of the inspection”.
The issue of the increasing awareness of the requirements of quality assurance schemes for food
producers is outside of the scope of the NIP. A range of stakeholders were consulted during the
drafting of the leaflet ‘How to safely spread sludge from your septic tank’
https://www.epa.ie/pubs/advice/water/wastewater/How%20to%20safely%20spread%20sludge%20fr
om%20your%20septic%20tank.pdf
A pilot scheme known as the GWS led Community DWWTS Education and Desludging Initiative was
undertaken by the NFGWS. The study concluded that with financial and other incentives a group
water scheme led community approach to desludging is a viable solution. The main findings of the
EPA funded research project have been included in the updated NIP (Section 4.4 Education and
Desludging Initiative).
“A pilot scheme known as the Group Water Scheme led Community DWWTS Education and Desludging
Initiative was undertaken by the National Federation of Group Water Schemes (NFGWS). It
commenced in 2016 and is due to conclude in 2018. The purpose of the study was to test the capacity
of group water schemes to co-ordinate and incentivise septic tank desludging for bundles of
householders. The main findings of the EPA funded research of relevance to the NIP indicate:
(i) Local authorities should provide a portal on their websites to the relevant information
including a list of registered contractors.
10(ii) Farming communities need to be better informed with regard to the proper disposal of
sludge on lands.
(iii) Contractors and farmers should be monitored by the relevant statutory agencies to ensure
that sludge is being properly disposed of.
(iv) The cost of sludge collection and disposal varies significantly from county to county based
on the rate per tonne at various WWTPs and the distance to the nearest facility.
(v) Reduced desludging costs will incentivise people to sign up to proper management of their
DWWTS. Significant savings (up to 50%) on the cost of desludging were achieved using
the community led bundled approach.
(vi) The bundled approach could also be applied to achieve cost savings for the proprietary
systems that require an annual service contract.
The study concluded that with financial and other incentives a group water scheme led community
approach to desludging is a viable solution. The findings of research will be published in 2018. Further
information will be provided on the NFGWS website at http://www.nfgws.ie/Home”
GRANTS
Issues raised:
A lot of the submissions received requested a review of the financial support for home owners to
assist in the remediation of DWWTS.
Response:
The Department of Housing, Planning and Local Government (DHPLG) is responsible for the provision
of funding for the grant system and for the setting of the eligibility criteria. The grant system is
currently under review. The EPA has forwarded a list of the submissions received in relation to the
grant system to the DHPLG. More information on grant eligibility criteria can be found at this link
http://www.epa.ie/water/wastewater/info/grants/
PRIVATE WELLS
Issues Raised:
A comment was received that although the focus currently is on DWWTS that pose a threat to water
bodies that particular consideration should be given to DWWTS that may pose a threat to drinking
water supplies.
It was recommended that the importance of testing household wells should be more emphasised in
the plan and that testing should coincide with the testing of DWWTS to verify the effectiveness of the
remediation works and provide data to inform future policy.
11Response:
DWWTS that may pose a risk to drinking water supplies have been considered as part of the risk
assessment methodology. Table 2.1 of the NIP outlines the criteria that were used in the
development of each of the risk zones. Double the number of inspections are required in areas
identified as having an increased potential risk to groundwater supplies from DWWTS.
The monitoring of the quality of private wells is outside of the scope of the NIP. Householders are
responsible for monitoring the quality of their own well water. The EPA has developed the ‘Protect
Your Well’ application to assist private well owners. It provides a step by step guide on how to inspect
your well for contamination.
In light of the comments received in relation to the risks to the water quality of private wells an
additional appendix (Appendix C - Information For Private Well Owners) has been included in the NIP.
The appendix includes links to the following information sources which may be of assistance to
private well owners and local authority inspectors.
“Information in relation to testing and treatment options for your private well is available at the
following link http://www.epa.ie/water/dw/hhinfo/testtreat/.
The EPA will continue to provide all local authority inspectors with copies of the leaflet “Have you
checked your well water supply?” a link to the leaflet is provided here
http://www.epa.ie/pubs/advice/drinkingwater/SS%20Wells%20Web.pdf.
Grants are available from the Department of Housing, Planning and Local Government under the Rural
Water Programme for the provision or improvements to an individual water supply in a house. Further
details can be found at http://www.housing.gov.ie/water/water-services/rural-water-
programme/private-wells.
The ‘Protect Your Well’ application has been developed by the EPA to assist private well owners. It
provides a step by step guide on how to inspect your well for contamination or the risk of
contamination. It can be accessed via the following link
http://erc.epa.ie/water/wells/#.WoK3HE1LGUm”
ENFORCEMENT
Issues Raised:
One of the main issues raised was the lack of enforcement of advisory notices which can result in sites
that have failed inspection potentially posing a risk to the environment and human health for a
considerable time period after a home owner has been informed of the problem and instructed to
undertake remedial works. A number of parties commented that more rigorous enforcement action
is required to ensure remedial works are completed within a reasonable timeframe.
12It was requested that the findings of the 2016 NIP Implementation Report should be included in more
detail in the final NIP and include more details on compliance with advisory notices and any legal
actions to assist in increasing awareness of the consequences associated with poorly installed and
maintained treatment systems.
It was recommended that the NIP should set out a target level of compliance. Some suggestions were
provided to improve enforcement including (a) the publication of areas of non-compliance on the EPA
website (b) measures could be introduced for monitoring local authorities performance in addressing
non-compliance issues.
It was recommended that the advisory notice issued by local authorities must include practical and
cost effective options to allow home owners to meet the standards required.
Response:
As outlined in the NIP the closing out of advisory notices by local authorities requires improvement.
Information on the numbers of advisory notices issued and closed out are reported on an annual basis
in the implementation report. The most recent published figures can be found in the Domestic Waste
Water Treatment Systems: Fifth Implementation Report 1st January – 31st December 2016 Reports on
NIP implementation for 2016 and previous years are available at the following link:
http://www.epa.ie/water/wastewater/nip/nip2016implementation/ as outlined in Section 1.3 and 4.1
of NIP.
It is not proposed to go into the detail previously provided in the 2016 National Implementation
Report as part of the NIP. The main findings of the implementation report in relation to the
percentage of inspection failures due to operation, maintenance and desludging and the associated
risk to private wells have been outlined in Section 4.1 of the NIP. The issue of advisory notices
remaining open after the remedial extension date has been covered under Section 5.1 of the NIP.
The local authority Enforcement Policy Working Group has previously developed guidance for
inspectors on the close out of advisory notices. The allocation of adequate resources for the
inspection process and the closing of advisory notices is a matter for each local authority.
In response to the submissions received in relation to the closing of advisory notices Section 5.1 of the
final NIP has been amended as follows.
“The enforcement policy working group will be tasked with the establishment of a specific metric in
relation to the closing of advisory notices.”
The NIP does not go in to the detail of specific remedial options required following the issue of an
advisory notice. The question of which treatment technology should be used is site specific.
The sub section on ‘Home owners’ in Section 5.1 of the NIP has been amended. The following text
has been inserted.
“Guidance for home owners on the remediation and replacement of a DWWTS is available at the
following link http://www.epa.ie/water/wastewater/guidance/remed/”
13PLANNING PROCESS
Issued Raised:
It was suggested that the EPA advocate for control in the planning process to address the risks
relating to inadequacy of the soil to attenuate microbial breakdown, facilitate hydraulic dispersal and
incorrect siting relative to the location of private wells.
It was recommended that there should be a system of documented supervision at the design,
installation and commissioning stages for all new systems.
Concern was raised in relation to the proprietary systems being requested by planners and engineers
and the need to address issues such as the shock loading of biological treatment systems in holiday
homes and electric pumps being switched off.
A comment was also received in relation to the need for planning permission to replace a septic tank.
Some DWWTS are not located on the home owners site which raises issues surrounding their
replacement and access for maintenance purposes.
Response:
Planning issues are outside of the scope of the NIP. These issues have been forwarded to the DHPLG.
FUNDING FOR LOCAL AUTHORITIES
Issues Raised:
It was outlined that currently no funding is ring fenced for DWWTS inspections and it was suggested
that the EPA would be in a position to advocate to government for further funding for local
authorities due to increased levels of activity in either strand of the two strand approach.
Response:
The issue of funding for DWWTS inspections is outside of the scope of the NIP. This issue has been
forwarded to the DHPLG.
14METRICS / TARGETS
Issues Raised:
Clarification was sought from the EPA as to whether recommending the desludging of a DWWTS prior
to the inspection is best practice. Concern was expressed by the consultee in applying this metric as it
is not a clear measure of the number of failed inspections and the correct reasons for failure where
home owners have desludged before inspection.
One of the local authorities requested clarification as their minimum required number of inspections
had been reduced from the previous NIP. They requested clarification as to how this new figure will
be described in terms of targets met in relation to RMCEI and within the National Performance
Indicators Report.
It was suggested that the NIP should be more specific in terms of quantifying and developing
timelines for the detection and repair of malfunctioning DWWTS and that specific goals in relation to
addressing same by 2021 are clearly stated in the plan.
Response:
There is a general lack of awareness by home owners of their obligations under the Domestic Waste
Water Treatment Systems Regulations. Local authorities should use all opportunities to raise the
awareness of home owners to their obligations under the DWWTS Regulations including the issuing of
pre-inspection advice.
The undertaking of pre-inspections and issuing pre-inspection advice to home owners is considered
beneficial in terms of increasing home owners awareness and encouraging home owners to desludge
their DWWTS.
In relation to the minimum numbers of inspections required to be undertaken each year under the
NIP these have been specified in Table 3.1 of the NIP. This is the minimum number of inspections
that local authorities are required to complete.
COMPLAINT PROCEDURE
Issues Raised:
There were concerns expressed that it would be difficult for a person living in a rural area to use the
See it? Say it! app as the identity of the complainant might be made known.
Response:
There are other ways of making a complaint besides the app. A person making a complaint via the
National Environmental Complaints Line 1850 365 121 can request that their name and contact
details are kept confidential.
15Section 3.4 of the NIP, complaint section, has been amended to include the following text addition:
“Alternatively you can ring the National Environmental Complaints Line (NECL) 1850 365 121 or
contact the relevant Local Authority directly. More information is available on the EPA website at the
following link: http://www.epa.ie/enforcement/report/ “
INSPECTOR TRAINING
Issues Raised:
The provision of a liaison group for inspectors was recommended to promote consistency of approach
to inspections with refresher training within the plan period.
Response:
A Septic Tank Inspectors network is in place under the Network for Ireland’s Environmental
Compliance and Enforcement (NIECE). The Septic Tank Inspectors network distributes information to
inspectors and provides a forum for inspectors to communicate amongst themselves and share
information relating to DWWTS inspections and remediation options.
Section 3.1 of the final NIP has been amended to include the following: “All inspectors are required to
have completed the training in relation to the inspection of DWWTS prior to appointment.”
CODE OF PRACTICE
Issues Raised:
It was recommended that the review of the Code of Practice Wastewater Treatment and Disposal
Systems Serving Single Houses should involve a process of consultation with all stakeholders prior to
issuing of new guidance.
It was considered that the development of new treatment options in the next EPA Code of Practice
Wastewater Treatment and Disposal Systems Serving Single Houses may have an impact on the
inspection programme for example compliance with advisory notices. It was suggested that further
training will be required when the new Code of Practice is issued.
Response:
It is intended that the revised Draft Code of Practice will go for full public consultation. When the
Code of Practice is finalised, any impacts on the NIP will be considered by the EPA.
16RESEARCH
Issues Raised:
The need for further research into the use of microbial source tracking techniques and other
fingerprinting methods to establish the risk of well contamination from DWWTS was recommended.
This could then support the incorporation of local risk factors into site selection for the inspection
plan.
The integration of health data into the risk assessment model was recommended.
It was suggested that to bring about significant behavioural change that future strategies should have
a health based demographically focused message.
It was stated that research into phosphate recovery systems at domestic level should be supported so
that innovations that have an applicability at this level could be developed and rolled out.
Response:
The EPA is currently funding a research project (2012-W_MS-12) which deals with the impact of on-
site wastewater effluent on rivers and wells. This project is looking at microbial source tracking. This
research is currently being completed. The findings of this research may inform future revisions of the
risk based methodology for the NIP.
The NIP has utilised the available hydrogeological information to identify areas with increased
potential risk to groundwater supplies from DWWTS. The hydrogeological datasets used were (i)
groundwater susceptibility to percolation of MRP and Pathogens from DWWTS and (ii) likelihood of
inadequate percolation.
Research into phosphate recovery systems includes the EPA Research 189: Identification and
evaluation of phosphorus recovery technologies in an Irish context
http://www.epa.ie/pubs/reports/research/water/research189.html (Ryan, Boyce and Walsh, 2016).
This research did not specifically address recovery at the domestic level however it addressed issues
in terms of the recovery of DWWTS sludge at waste water treatment plant.
With respect to the comment on a health based demographically focused message. The Engagement
Working Group will consider the findings of the latest research by Hynds, P., Naughton, O. & O'Neill,
O. (2017) [Efficacy of a National Hydrological Risk Communication Strategy: Domestic Wastewater
Treatment Systems in the Republic of Ireland. Journal of Hydrology, no. 558, pp. 205-213.
doi.org/10.1016/ j.jhydrol.2018.01.041
https://arrow.dit.ie/cgi/viewcontent.cgi?article=1114&context=engschcivart] in terms of the
implementation of the engagement strategy
17CLIMATE CHANGE
Issues Raised:
A comment was received that no mention was made of climate change or carbon sequestration in the
NIP. It was recommended that specific guidance be included and that carbon sequestration and zero
energy input systems be recommended as best practice as part of any necessary upgrades as part of
the NIP process.
Response:
The NIP does not go in to the detail of specific remedial options required following the issue of an
advisory notice. The question of which remedial measures are to be used at a particular location is
site specific.
End.
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