This week, the Department of Housing, Local Government and Heritage (DHLGH) published the 3rd Cycle River Basin Management Plan (RBMP) Consultation Report. A 6-month long public consultation was undertaken on the draft RBMP from September 27th 2021 to March 31st 2022. A total of 1401 submissions were received by the DHLGH through a combination of the Department’s on online survey and direct email.
These submissions were initially categorised as submissions based on:
- Consultation Response Questionnaire issued by the DHLGH (161);
- Template response (original emanating from the Sustainable Water Network (SWAN), a network of environmental NGOs) (1172); and
- Individual ‘free style’ responses from a cross section of stakeholders (68). Of these 259 were identified as unique content.
RPS were appointed by the DHLGH to review these submissions. The questionnaire submissions were reviewed individually to provide a summary per question and an overall summary was then prepared for each question once all 161 submissions had been reviewed. In addition, key themes raised were noted for each submission.
The main template submission was initially reviewed for content and any variations of the template were also reviewed to identify additional issues. Key themes raised were recorded.
For the final category of “free style” each submission was further categorised as:
- Government Department/Agency/Body;
- Local Authority;
- Non Governmental Organisations (NGOs);
- Community Groups;
Each submission was then reviewed and summarised and key themes raised were recorded. Thirty-eight themes were identified across the 259 submissions reviewed, the ten key issues raised within the ten most prominent themes are listed below.
It is interesting to note that 4 of these issues relate to pressures on water bodies such as pollution, agricultural practice, forestry and sewage discharge whereas 6 of the issues of most concern relate to level of ambition, public engagement, policy coordination, plan implementation, resources including training and funding and enforcement.
These findings reflect the Forum’s submission where we called for an outcomes based-approach whereby measures would be identified for each waterbody to allow for transparency and accountability across the implementing bodies and agencies.
We recommended that there should be a project management secretariat to lead on the implementation and monitoring of the new plan and to ensure the collaboration between the different agencies and departments to ensure that the national and catchment management plans reflect policy coherence and alignment with outcomes for water, nature and climate.
The Forum supports the development of a new national approach to public participation, beginning with a phase of piloting different approaches, to allow for meaningful public engagement in the development of the 46 catchment plans. A framework will need to be developed to support such structured engagement including training and resources for action and outcomes at catchment and local authority level.
A total of 113 recommendations were made to cover these outcomes and in relation to the individual pressures affecting WFD status of waterbodies.
These considerations will contribute to the final 3rd cycle of River Basin Management Plan (RBMP) for the period of 2022-2027 currently being finalised by Department of Housing, Local Government and Heritage (DHLGH) in line with the EU Water Framework Directive (WFD) (2000/60/EC).
The report is available at:
The Water Forum submission to the consultation is available at: