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Subject: RBMP Consultation

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Dear Sir/Madam,

I am very concerned that half our rivers, lakes and estuaries are unhealthy, with river pollution increasing. I do not believe the proposed River Basin Management Plan will fix this; I submit the following recommendations:

1. The plan must be far more ambitious and include targeted measures to restore ALL waters to healthy status by 2027 and halt deterioration.

2. Agriculture policy must be brought in line with the Water Framework Directive (WFD) to halt escalating pollution through a WFD-specific risk assessment for all intensive farms, including derogation farms, as part of a permitting system. 

3. Prohibit wetland drainage and implement a national wetland restoration plan.

4. The Irish Water Investment Plan must end sewage pollution from all the wastewater treatment plants identified as the main pollution source in over 200 waterbodies.

5. Afforestation and felling licenses must include a WFD-specific assessment, with site-specific conditions to protect water. Afforestation on peat soils in acid sensitive catchments must stop.

6. The Plan cannot ignore the coast. It must set out all coastal-specific pressures and the measures to address them.

7. Water governance must be made transparent and brought into compliance with the Aarhus Convention. Participation of the public and local river groups in the development of catchment management plans must be facilitated & resourced.


Kind regards,