Given the recent announcement by Irish Water that it is considering diverting the River Shannon to Dublin to cater for anticipated water shortages, the River Shannon Protection Alliance (RSPA) wishes to make it clear that any such proposal will face the strongest opposition to such needless, high risk, and outmoded infrastructural planning. This Irish Water/Dublin City Council proposal (the third attempt in recent years) would extract water at a rate of hundreds of millions of litres per day (MLD), and there can be no doubt that rates of abstraction will increase exponentially year on year, with disastrous consequences economically, environmentally, and socially for all of the communities along the full length of the Shannon.
Dublin does not now have a shortage of water, and it need not do so in the future. Current supplies are more than adequate for current demand, however Dublin City Council (DCC) has been throwing half of it away through years of leak ridden supply pipes and creaking treatment facilities, all of which have suffered from decades of neglect and under investment. Injecting Shannon water into such a system would result in wastage of most of this new supply, while delivering only marginal improvement. On the other hand, reducing leakage rates to international standards would double existing supplies.
If the day ever comes when Dublin needs additional supplies of water, there will never be a need to come to the Shannon. There are abundant supplies closer to home which can be availed of more easily and at a fraction of the cost of the current proposal. Shannon abstraction would require a pipeline in excess of one hundred miles in length, at a cost to taxpayers in the region of one billion Euros. At the same time a range of supply options exist on Dublin’s doorstep waiting to be tapped. An estimated 100 million litres per day of high quality ground water is available sustainably from the Fingal/Meath/Kildare aquifer. Additional reservoirs can be built closer to Dublin. Desalination can provide unlimited supplies indefinitely, and it is becoming more and more cost effective with the introduction of new technologies e.g. reverse osmosis. Additionally, there is massive potential for water savings in Ireland through conservation measures. Just one example alone was a dramatic drop in consumption in the Dublin area recently, when it appeared that usage-based bills were about to issue from Irish Water in April.
Irish Water www.water.ie are currently calling for submissions regarding these proposals, and the RSPA will be responding robustly, questioning all of the assumptions and forecasting on which a new Dublin supply and Shannon abstraction are based. We call on all public representatives to consider their constituencies, and also on members of the public, to submit their views on this critical issue.
Finally, on this WORLD WATER DAY (March 22nd.) it is worth reminding ourselves that:
70% of Earth’s surface is covered by water.
97.5% of that, is sea water, leaving 2.5% as fresh water.
70% of fresh water is locked up in the ice caps of Antarctica and Greenland, and underground aquifers which are too deep to be accessible.
Only 1% of the world’s fresh water is accessible for human use. Found in rivers, lakes, and reservoirs.
“WASTE NOT WANT NOT”
Like that of many cities Dublin’s water requirement is growing at an unsustainable rate. The current suggestion to extend Dublin’s water footprint as far as the River Shannon needs to be challenged. Depleting the supplies of donor sources entails an ever increasing cost in construction and ongoing electrical energy for pumping vertically and laterally.
Before committing to such a solution much more consideration must be given to: (a) reducing consumption (b) reducing wastage (c) re-use and recycling of waste water and storm water run-off (d) capture-and-hold systems using barrels and underground cisterns.
On the capital’s geographical doorstep we have the Wicklow/Dublin mountains, the country’s largest area of continuous high ground with its numerous valleys and ribbon lakes. Thanks to the ice age many of these corry lakes are separated from each other by small morains which if required could be easily breached by channelling or piping.
So why should we have to re-invent the hydrological wheel when we already have the solution to hand? The Vartry scheme was built in the 1860s, Bohernabreena in the 1880s and Poulaphouca in the 1930s. Leave the Shannon alone. What is required is to raise the level of the existing reservoirs and/or build new ones. One way or another, all that is needed is cement, pipes and cop-on. The multitude of rivers and streams exiting these lakes would not be adversely affected since excess run-off during heavy rains ends up in the sea anyway.
I would like to say that this submission is only to support the more substantial submission by the River Shannon Protection Alliance ( R S P A) . As a county Councillor I would like to add my voice to the wrongful assumption that the problem with lack of Water in the Dublin region can be sorted by sourcing water from another region 100 miles away . This is wrong for many reasons as the money would be better spent by fixing the up to 50% leakage rates in Dublin . a simple 15% reduction of leaks would save 100MLD of water per day . The Lough Derg/ Shannon abstraction would place a high and unsustainable cost on the mid west region in terms of the economic and social cost and the river and its tributaries would suffer ecologically and environmentally . It should be noted that Lough Derg is a protected under the European framework directive and is a protected Natura 2000 site under both the birds and Habitats directives. . The abstraction proposals are being costed as free abstraction which is wrong as Tipperary county council has a development CONTRIBUTION levy in place put there at my request which puts a cost on Abstracting water from the county.
The abstraction of water from the Mid West to Dublin is against spatial planning as it will promote unsustainable development in the Dublin region while weakening the Mid west region. The damage caused by abstraction will cause irreversible ecological damage to the plush farmland surrounding the lake and will actively damage our agricultural, tourism and economic viability of the region and is totally against balanced regional development of the country. Lough Derg is of huge economic importance to the future economic sustainability of Tipperary and I am vehemently opposed to the proposed water abstraction of Lough Derg river Shannon.
Yours sincerely Cllr. Séamie Morris 03/08/15
By River Shannon Protection Alliance (RSPA)
Water supply is measured in megalitres per day (MLD), which equals 1,000 cubic meters. For comparison, a standard Olympic size swimming pool is normally considered to be 2,500 cubic meters in volume or 2.5 MLD. A combination of capital expenditure (CAPEX – infrastructure spending plus financing costs) and operational expenditure (OPEX), divided by the amount of water delivered in a project lifespan (25 years in this case) gives the lifetime cost of water delivered in €/m3 or, alternatively, if comparing investment options, €/MLD (delivered). The discount rate used for such public infrastructure projects is 5%. The capacity of a treatment plant refers to its maximum output in MLD, while the load factor refers to how much is actually delivered in percentage terms within a given time frame.
Raw water is the water that enters a treatment plant and treated water is what exits the plant and is fed into the mains distribution network. The treatment process itself is straightforward; involving coagulation, sedimentation, filtration, chlorination, fluoridation, and sometimes UV light. Surface water relates to rivers and lakes while groundwater is contained within the ground and accessed by wells.
Demand in the Greater Dublin Area (GDA), including large parts of Kildare is around 540 MLD and it took 1,000 years or so to reach this figure. According to Irish Water’s figures about one third of this figure or c. 180 MLD is due to leakage from both the distribution (mains) side and customer side. Future water demand studies carried out by consultants acting for Dublin City Council (DCC) greatly underestimated requirements in the early 1990s, and overestimated requirements in the mid 2000s, based on unsustainable Celtic Tiger growth rates. A study in 2006 predicted GDA demand in 2015 would be 615 MLD, when in fact it had plateaued since 2007 at around 540 MLD. In such a short space of time the presumably expensive consultants were out by around 75 MLD in their estimations. A number of the people involved in this now work for Irish Water. In the meantime, and contrary to what many leading figures are saying, there has been a lot of investment into securing additional supply with a major stand-alone 80 MLD extension to the Leixlip water treatment plant finished in 2014, and also a 40 MLD plant on the River Barrow near Athy finished in 2013. This should bring the total available capacity figure up to around 660 MLD; with the main sources being Ballymore Eustace at 318 MLD, Leixlip at 215 MLD, Varty at 75 MLD, Ballyboden at 16 MLD, and the River Barrow at 40 MLD.
The whole idea for a new River Shannon supply source for the GDA comes from this now discredited work in the mid 2000s where a figure of 300 MLD was
considered to be necessary for any new source. As the intervening years have shown, there is no reason for any one particular raw water supply option to have to be able to provide such a high figure – it is nonsensical in the current context. Unperturbed, the powers that be, who now reside in Irish Water, have ploughed ahead on this one option, ignoring a broad range of more flexible and cost- effective supply-side and demand-side solutions. A soon-to-be-announced final option chosen by Irish Water is to treat and pipe water around 150 km from the Parteen Basin on the River Shannon to the GDA network. The capacity of the scheme is said to be 330 MLD. This will probably have a CAPEX in the region of €800 million with a 25 year OPEX of €200 million, so a lifetime cost of €1 billion or so. In fact, very significant amounts of money are already being spent. According to www.cer.ie, Irish Water’s allocation to the planning and business case review for the Shannon Scheme between 2014-2016 is €6.96 million, presumably much of which is going on consultancy fees.
In order to justify the scale of the project, Irish Water has decided to think in terms of a ‘National Water Spine’ and ‘Benefitting Corridor’. At present, there is no raw water supply issue in the midlands and any local water treatment issues are due to the poor allocation of resources and historic underinvestment so the RSPA consider this appendage to the overall project to be a red herring. Irish Water have claimed that the Shannon Scheme will reduce water supply risks to these areas but the RSPA does not believe that a singular source for much of the country represents less of a risk than multiple sources. What if something goes wrong with the proposed Shannon Scheme raw water source or plant infrastructure?
If we divide the €1 billion above by the number of households in Ireland at around 1.6 million, we get a figure close to €600 per household towards this one scheme. This is a major investment so let us see how the figures compare to other options. If we take the best case scenario of the Shannon Scheme operating at full capacity, the figures work out at around €3 million/MLD. The reality, though, is that it is very unlikely that anywhere near full capacity would be required for a very long time. A more realistic figure would be that only one third of its capacity or 110 MLD would be required on average over its 25-year lifetime (33.3% load factor). This would mean that the figure above jumps to €9 million/MLD. The equivalent figure in this scenario in terms of cubic meter lifetime costs would be around €1/m3. This is extremely high for water treatment.
By way of comparison, the recent stand-alone extension to the Leixlip water treatment plant cost €30 million for 80 MLD or €0.375 million/MLD at full capacity. This is 8 times cheaper than the Shannon Scheme in a best-case scenario (from an IW perspective) and around 16-20 times cheaper in a probable scenario. In documents exchanged with RSPA, Irish Water have stated that the average cost of repairing mains-side leaks is €7-8 million/MLD, while the figure given for customer-side leaks is €0.75 million/MLD. Why one is ten times the other is not explained and does not seem credible. Regardless of this and according to these figures, fixing customer-side leaks is 4 times cheaper in a
best-case scenario and 12 times cheaper in a probable scenario. For additional comparison, a recent 10 MLD groundwater supply scheme in Co. Waterford was carried out at a cost of around €0.65 million/MLD, nearly 5 times cheaper in a best-case scenario and 12-15 times cheaper in a probable scenario.
In a previous report, consultants for DCC had identified over 100 MLD of groundwater as being available within an 80km radius of Dublin. One existing well alone in the Curragh aquifer has a documented yield of around 2.5 MLD. As far as RSPA are aware, Irish Water and DCC before them have not even drilled one dedicated exploration borehole to determine the potential yield from new groundwater sources in the GDA region – the supposedly in-depth study that was undertaken was a desk study.
For a number of reasons ranging from the economic to the environmental, the RSPA opposes this project and will fight it all the way if necessary. Due to the continued operational regime of the ESB hydropower plant at Ardnacrusha, the old River Shannon below the Parteen Basin can already be described as a sick river. Detailed environmental arguments can be put forward against the proposed extraction at very low river levels, which is when the GDA would be requiring their greatest level of abstraction. What is the point of developing these arguments, though, if the economics of the project are so bad? For anyone who thinks that such a scheme would help alleviate the now frequent lower Shannon flooding, the effects of pumping water away through such a scheme would be miniscule, probably much less than 1% of peak river flows, and occurring at a time when the extra water will not be wanted in the system anyway.
1. Halt Shannon Scheme development
2. Fix 50 MLD worth of leaks in the GDA at a probable cost of €150 million
or less – results within 1 to 3 years.
3. Develop 50 MLD groundwater supplies in nearby regions (e.g. Curragh
aquifer) at a probable cost of €75 million or less – results within 3 to 5
4. Once either of the above has been carried out, undertake the necessary
overhaul of the vulnerable Vartry supply system.
5. Upgrade any issues in current midland water supply plants as needed
6. Save in the region of €500 million in the medium term and spend this in
other areas that are crying out for investment
7. Review the situation in 10 years time with numerous other flexible
options available for further future water supplies
Or, let Irish Water carry on with their current hyper-expensive single solution Shannon Scheme that would be unlikely to deliver one drop of water for at least another 7 years, although more likely 10 years.
Irish Water has signaled it intention to apply for planning permission to divert River Shannon water to Dublin for domestic, commercial and industrial consumption. It proposes to construct a 172 kilometer pipeline from the Parteen Basin to Dublin, at a cost of 1.2 billion Euros, to transfer hundreds of millions of liters of water per day. The RSPA and other organizations, stakeholders and interested parties are pledged to strongly oppose this extravagantly priced, and needless mega scheme, and are determined to expose it as a reckless, high risk and outmoded method of providing water to consumers. In a forensic examination of Irish Water’s plan, the ‘Kennedy Report’ found that “This project will almost certainly prove to be an unnecessary White Elephant and a huge waste of Irish people’s money”. The summary page of the Kennedy Report is given below, and the full report is available on the RSPA website, www.shannonprotectionalliance.ie
THE KENNEDY REPORT: A SUMMARY
For some time Irish Water has been proposing to spend up to EUR1.2billion (EUR724 for every Irish household) on the Shannon project - an ill-conceived scheme to pump water 172km from the Shannon to Dublin. This project will almost certainly prove to be an unnecessary White Elephant and a huge waste of the Irish people’s money – at which point the many errors made in this process will come into sharp focus and those individuals who (explicity or implicitly) rubber- stamped the project will be answerable to the Irish public.
Irish Water predicts that, by 2050, Dublin will have a water deficit of 214.7Ml/d (million litres per day) but the report on which this is based contained basic and fundamental errors, inappropriate methodology, and flawed assumptions. In fact, by 2050, there will almost certainly be a raw water surplus of over 100Ml/d without having to increase existing raw water supplies at all.
Dublin has no shortage of raw water. Its problems (and its recent water crises) have been due to Victorian-era water infrastructure with a history of under-investment resulting in insufficient capacity to treat/deliver water. Irish Water is finally investing in Dublin’s water infrastructure – recent upgrades at two water treatment plants have drastically (and inexpensively) improved their water treatment capacity and more improvements are underway. Dublin has a total leakage rate in its water network of over 40% (comparable to Mexican cities) so for every litre of precious treated water put into Dublin’s water pipes almost half of it ends up in the ground. Leaks are now infinitely easier to identify/fix post- the introduction of meters. Water savings as a result of Irish Water’s ongoing First Fix programme have far exceeded expectations, for a fraction of predicted costs. Focus needs to remain on improving Dublin’s ability to treat and deliver its plentiful supply of raw water: this scheme to source extra water from the Shannon is an unnecessary waste of money.
If, at some point in the future, Dublin does need more raw water then local groundwater is the best option. Groundwater is inexpensive, can be developed incrementally as needed (whereas the Shannon project is “all-or-nothing” - not a drop of water can be delivered until the EUR1.2billion ten-year mega-project is completed), reduces contamination risk (sources are diversified, rather than all coming from one source as with the Shannon project) and drilling wells is something in which we have hundreds of years of experience. Even the Geological Survey of Ireland (Ireland’s main authority on groundwater) made a submission during consultation for this project that “the use of groundwater should not be overlooked...it has a number of advantages over the use of surface water. It is a viable and widely available resource that would be relatively inexpensive to develop at a local level” and yet during this process groundwater was dismissed as an option without a single test borehole having been drilled and Irish Water’s review of the groundwater report contained basic mathematical errors that rendered its main conclusion wrong by 33%.
The Shannon project needs to be put on hold immediately and re-assessed on the basis of a correctly framed “demand” prediction taking account of improvements to Dublin’s water infrastructure and thorough, accurate investigation of groundwater.