Response to the Public Consultation on the Flood Risk Management Plan for theSouth Eastern River Basin District, UoM 12

We/I welcome the opportunity to comment on the draft Flood Risk Management Plan (FRMP)for UoM12 and would like to set out our/my main areas of concern with the draft Plan.

  1. Ineffective Public Participation
  • Engagement has been limited to consultation and information exercises only.
  • Little has been done to encourage active involvement of the public.
  • The consultation period is too short, limiting the ability of members of the publicto read, understand and respond to the lengthy complex plans and environmental reports.
  1. Impacts on the Water Environment
  • The Strategic Environmental Assessment has identified that the preferred structural measures would have significant negative impacts on water quality, the aquatic environment, aquatic species, biodiversity and fisheries.
  • There would also be significant negative impacts on water-dependent Special Areas of Conservation (SACs) and Special Protection Areas (SPAs).
  • There is a reliance on/presumption that mitigation will be properly implemented to offset impacts, despite evidence of ineffective mitigation on past and current projects.
  • It would appear that measures proposed in the draft Planshave not been included in the Water Framework Directive (WFD)planningprocess.
  • There is no indication in the FRMPs, or in the public domain, of ongoing collaboration between scientists working on implementation of the Floods Directive with those working on the WFD.
  • There are hardly any ‘win-win’ measures, such as Natural Water Retention Measures, that would benefit both the Floods Directive and WFD objectives.
  • The Plans are missing an integrated catchment management approach.
  1. Reliance on Existing Planning/Consent Process
  • There is an over-reliance on current planning and/or consent processes, despite weaknesses and examples of damage to rivers by flood protection works under the current system (e.g. the Bandon River (Dunmanway) Drainage Scheme).
  • Development in flood-prone areas can still proceed.
  • There is still no review of the Guidance on Site Development Works for Housing Areas, which was to set out best practice in regard to the use of Sustainable Drainage Systems for surface water drainage.
  1. Lack of Integrated Governance/Fragmented Approach to Floods Management
  • There are currently no mechanisms to facilitate integrated water management decisions at a catchment level, including for flood management.
  • It is unclear from the Plans where responsibility for implementing them lies: The OPW is responsible for implementing the Floods Directive, Local Authorities decide whether to adopt the Plans but their role in implementation is unclear, and various organisations have the responsibility of implementing the measures.
  1. Additional Comments
  • Insert any additional points you would like to make or delete this section.