Water Framework Directive Northern Ireland 2010

Water Framework Directive: River Basin Management Plans     A  Response  by Brendan Kerr , Natural Living Assets 

 Thank you to Environment and Heritage Service who organised numerous consultation evenings and workshops to address the issues. It is hoped that the outcomes and feedback from these meetings will be listened to and acted upon to contribute to a Sustainable Northern Ireland that looks after its natural river basins and water courses.

Scientific Approach

EHS have adopted a scientific approach to the strategy and have presented their findings regarding monitoring of rivers as Chemical, Ecological and Morphological. However a few issues remain unaddressed and the results of such analysis need to be analysed holistically.

Targeted Commitments

Scientific monitoring and practice enhances good communication. However interventions are demanded to ensure that the fruits of analysis and monitoring are achieved by improving water and habitat quality. That needs a commitment beyond the analysis, to pursue environmental strategies that offer sustainable and socio economic benefits.

Socio economic gains

Natural Living Assets represents socio economic gains that can come from abundant stocks of trout and salmon populations. Future abundant stocks need more than chemical, ecological and morphological analysis.

Productive Habitats

Productive habitats are also needed. Fish populations have been compromised over many years and little regard has been given the specific needs of fish populations in Northern Ireland. There are a few examples of best practice such as the work carried out at Bushmills Salmon research station. However there is a very high risk that the fruits of that research will be compromised by impaired water quality, as there often is on the river Bush. In fact sections of this river are of poor water quality which poses a risk to a fragile salmon and trout population.

High, Good, Moderate, Poor, Bad water quality

Specifically the number of rivers where water quality is planned to achieve the High category is disappointing and this should be addressed within the consultation review. 

Opportunity Cost and Targets for High Water Quality

The cost of missing the opportunity to achieve ambitious targets for rivers in Northern Ireland (NI) needs full consideration. The impact of the economic downturn makes achieving sustainability of the unique river basins in NI more urgent. Specifically the targets need to be reviewed to achieve a larger number of rivers in the High category, specifically for those rivers with significant Atlantic salmon and sea trout runs. The rivers of the Glens of Antrim for example!    


The River Basin Management Plans need to provide milestones towards better managed rivers, beyond simply measuring parameters and pollution incidents.

For example what steps will be taken to achieve planned aims utilizing opportunities for “New Green Deal” and  “green collar” employment.

Adding Value

Where a river within its catchment adds or has the potential to add to the local socio economic value of the local economy by protecting the Atlantic salmon and sea trout resource then the priority to enhancing quality habitat should be increased.

Local Initiatives

Any decisions to move forward on plans need to take account of local initiatives being pursued by local groups including angling clubs, which strive to add value. Cooperating with local groups led by sustainable policies will lead to a better environment for all and engender a sense of responsible stewardship.

Valuing a river for its natural living resources and adding value

Each river in the country will have unique living resources which forms an ecosystem and that these same resources may be currently undervalued. The context for making decisions to drive forward a particular action plan needs to fully value such assets.

Habitat enhancement and chemical monitoring

P.19 “for each water body, the ecological quality elements were rated individually. Chemical quality was determined by the levels of certain hazardous and dangerous chemicals. The ecological and chemical results were combined to give overall status e.g.

High good moderate poor bad

Much more weight needs to be given to habitat protection and enhancement.

Chemical analysis that points to good water chemistry simply because the measurements were taken at a time when the evidence has been washed away is unacceptable. Whilst Chemical Quality has been combined with ecological and morphological scales to produce assessments and plans more thought is required to define a context for guiding decision making.

Salmon rivers

There are many important salmon rivers that are compromised in their ability to produce a sustainable salmon and sea tout run. There are others very close to disaster, where a pollution event could undo recent habitat and stock improvements. Given that salmon rivers have suffered from poor decision making regarding river basin management over many years we need to move urgently to a system that looks forward to more abundant stocks.

The following need to be considered in future plans

*Habitat Protection

*True contextual value of habitat

*Ecological value/ Ecological added value

*Ecological opportunity cost

*Trans- departmental communication

*Adding value role for Angling Clubs and community groups

*Development of community based rivers trusts

*Liaison communication and understanding with other groups

*Commitment to policing and environmental leadership.

*EHS needs to give leadership to support the community in its aims to take                        responsibility for environmental and community policing.

*Commitment to empower local communities to be educated, learn and deliver on meeting needs for River Basin Management Plans.

*Socio economic factors need to be incorporated into decision making.

*Specifically the value of sustainable fish, fisheries and angling tourism.

*Leadership in NI. Communication with other agencies.

*Factoring in economic and socioeconomic value for the added benefits of clean               rivers.

*Clamping down on litter and general use of rivers as a cheap facility for Fly –                  tipping!

*Time frame for implementation

*Continued support for Nitrates Action Programmes &Farm Payment schemes

*Capital works programme NI water

*Strategic Environment Assessment Directive

*Nautura 2000 and ASSI designation

Every little hill stream is significant. Need to fix the big picture by local initiatives to fix little things. Little cumulative actions will contribute to a holistic improvement.

Angling clubs need to be recognised as key vested interests in improving the quality of water and riverine habitats.

Specifically rivers in the Northern Ireland need to maintained and progressed toward high water quality. Angling clubs and local communities groups all benefit form healthy rivers.

We have fantastic rivers for Atlantic salmon and sea trout in NI from Glens to Bush Bann, Foyle and Erne. We now have a tremendous opportunity to develop our rivers sustainably and in a way that will add value to the future and future generations.

I hope that this feedback will be listened to and that EHS will respond to ensure that the River Basin Management plans achieve a best possible solution to maximize the future value of these of these fragile resources. There is no doubt that water courses in Northern Ireland have been neglected and impaired in their quality for many years and the challenges are great. The water Basin Management plans can provide a way forward.

Brendan Kerr

Natural Living Assets


3 Greenridge Park


BT19 6AN

07852 685 854

0044 (0) 7852685854

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