Water Consultation Response NI

Response to Consultation:

Environmental and Social Guidance for Water and sewage Charges

Brendan Kerr

Natural Living Assets


3 Greenridge Park


BT19 6AN

07852 685 854

1.6 It is interesting that “no disproportional impact between rural and urban investments has been identified.”

Context: Urban or Rural

The context for rural and urban settings may be different and this will need further analysis. The WFD directive consultation will provide some of these answers.


What provisions and plans have has been made to incorporate the Water Framework and river Basin Management Plans in any decision making process?

Water is not just for drinking, washing and carrying away effluent. The added value services are critical to the functioning of local communities in both rural and urban impacts. Rural ways of life and rural economies will have a greater relative value attached to the extra service provided by natural water.

High Standards

Drinking Water Standards need to be high and the public confident that they can drink freely form the local water supply. Given the amount of plastic manufactured and dumped to dispose of plastic water bottle containers it would make good economic and sustainable sense to ensure drinking water is of the highest quality. Drinking water should be feely available to the general public in their homes and dwelling areas.

Added Value Water Services

Thoughtful analysis and objective consideration needs to be given to the added value of water services. This needs to be done in the context of each catchment, river, water source and local area. A general broad-brush approach will not optimize outcomes. Each local area will have its own requirements and look to central agencies such as NIW for advice. NIW needs to embrace this need and avoid silo decision making that compromises greater good decision making. Specifically the needs of natural habitats and the sustainability of valuable endogenous fish species such as salmon and trout need to be accommodated. Natural habitats and their ability to add economic value need to be given the priority they deserve. The “opportunity cost” of well thought out decision making and resources applied will produce long term benefits, particularly since natural habitats are more and more valued and desirable.

Consideration needs to be given to water management impacts that add to the cost of providing additional value added water services, and the requirement to provide sustainable added value.


What provisions have been made for broader socio economic consequences?

Specific targeted strategies are required so that rivers and water sources are not de valued for their amenity and habitat. The needs of other water users in relation to local Geographic and socio economic circumstances need to be factored in to the decision making process. Decision making process needs to be holistic to achieve a competitive Northern Ireland. Management plans need to incorporate the water framework directive and community needs for sustainable best practice including habitats, fish stocks (salmon and trout).


Summary of comments

Added Value

Water value is greater than it use as a commodity to drink and utilize in domestic processes, agricultural processes, industrial processes and to carry away waste.

Water Framework Directive

WFD and river basin management plans needs to be fully integrated into decision making.

European Union Transposition

 Local EU Transposition processes need to be managed openly so that local consequences and impacts are fully considered   


EU responsibilities in law and for the greater good and the desirability for greater good services need to be considered.


Partnership working

Working in partnership with other environmental agencies to achieve water objectives that provide efficiency, excellent management of waste streams and which encourage to promotion and development of water added value.

Opportunities to kick start the Economy

More investment in emptying service for anaerobic digestion for silage could help ignite a faltering economy and provide much needed “green jobs” and investments.

Aim to promote technologies for the removal of sewage / sludge / slurry removal as an environmental service to improve the quality of added value water services.

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