For many years now the Association has been complaing about the filamentous algae pollution of the Liffey at Ballymore Eustace and further downstream. The Ballymore Eustace Trout and Salmon Anglers’ Association is convinced that the cause of this pollution is nutrients from Blessington Waste Water Treatment Plant (WWTP) which discharges into Golden Falls Lake. The following is a summary of correspondence which has passed between the Association, EPA and Wicklow County Council in our ongoing efforts to rid the Liffey of this pollution. (See also Blessington Sewage Plant Discharge into Golden Falls)

Ballymore Eustace Trout and Salmon Anglers’ Association
Barrack Street,
Ballymore Eustace,
Co. Kildare.
13th April 2009

Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate,
McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir,

On behalf of the above Association I wish to complain about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. While we are keeping our fingers crossed that this scum like algae is not having a detrimental affect on the spawning gravels or aquatic fly life, it is seriously reducing the recreational value of the Liffey and is totally unacceptable.

Analyses figures for the first seven months of 2007 reveal very high levels of total phosphorus (up to 0.55 mg P/l) in Golden Falls Lake and we believe that this is the cause of the algae bloom in the River Liffey immediately downstream of Golden Falls and continuing for a number of miles downstream.

While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.

The Association requests the Environmental Protection Agency to examine the situation with a view to having the phosphorus concentrations in Golden Falls Lake reduced to acceptable levels that will not pollute the Lake and the Liffey.

Yours sincerely,

___________________________
Gary Bolger
Honorary Secretary

Ballymore Eustace Trout and Salmon Anglers’ Association

Barrack Street,
Ballymore Eustace,
Co. Kildare.
18th May 2009
Mr. Joe Boland,
Director of Services,
Kildare County Council,
Aras Chill Dara,
Naas.

Dear Joe,

Please find enclosed some photographs showing the algae growth on the River Liffey, upstream of Ballymore Eustace Bridge on Friday 15th May 2009.

This algae is seriously reducing the recreational value of the Liffey and is making angling impossible.  It is impossible to retrieve angling flies through the water without them being totally covered in this algae scum.

We also believe that the algae growth is harming the spawning gravels and aquatic invertebrates.

This algae growth has been present on the Liffey since at least the beginning of March 2009, the start of the angling season.

We believe that the cause of this algae growth is the excessive nutrients in the water due to the Blessington WWTP discharging into the Golden Falls Lake. As we have stated before, Golden Falls Lake is unsuitable for the discharge from Blessington Waste Water Treatment Plant.

Something must be done to remedy this pollution of the Liffey by Wicklow County Council.

Yours sincerely,

_________________________
Gary Bolger
Honorary Secretary

 

Copies to:   Mr. Eddie Sheehy, Manager, Wicklow County Council
Ms. Majella Henchion, Plant Manager ESB Turlough Hill
Mr. Pat Doherty, C.E.O. Eastern Regional Fisheries Board
Office of Environmental Enforcement, EPA

Ballymore Eustace Trout and Salmon Anglers’ Association
Barrack Street,
Ballymore Eustace,
Co. Kildare.
19th April 2010
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate, McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir/Madam,

On behalf of the above Association I wish to complain in the strongest possible terms about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. This scum like algae on the surface is seriously reducing the recreational and aesthetic value of the Liffey and is totally unacceptable.  Since there is also a filamentous algae covering the gravels it is impossible to say that it is not harming the aquatic invertebrates and fauna in the Liffey.

The Association reported a similar algae growth to the Office of Environmental Enforcement by letter dated 13th April 2009 but no action to remedy the pollution has to our knowledge been taken by the EPA, Wicklow or Kildare County Councils.  This is totally unacceptable.

Analyses figures from Wicklow County Council for the first seven months of 2007 (the only figures available to the Association) reveal very high levels of total phosphorus (up to 0.55 mg P/l) in Golden Falls Lake and we believe that this is the cause of the algae bloom in the River Liffey immediately downstream of Golden Falls and continuing for a number of miles downstream.

While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.  The ESB control the water flow through the Lake.

The Association requests the Office of Environmental Enforcement, Environmental Protection Agency to take immediate action to rid the Liffey of this horrible pollution.  Indeed it is time the EPA took a much firmer stance on all the sources of pollution to the Liffey in Ballymore Eustace.

Yours sincerely,

___________________________
Gary Bolger
Honorary Secretary

Copy:  Mr. Eddie Sheehy, Manager, Wicklow County Council
Mr. Michael Malone, Manager, Kildare County Council
Mr. Padraig McManus C.E. Electricity Supply Board.
Mr. Pat Doherty, C.E.O. Eastern Regional Fisheries Board.

Reply from

Dublin City Council
Comhairle Cathrach Bhalle Atha Cliath
Project Management Office, Environment & Engineering Department,
Block 1, Floor 4, Civic Offices, Wood Quay, Dublin 8.
Olfig Bainistfocht Tionscadal, Roinn Comhshaoil agus lnnealtoireachta,
Oifigi na Cathrach, An Che Adhmaid, Baile Atha Cliath 8.

Mr. Thomas Deegan,
Honorary Secretary,
Ballymore Eustace Trout and Salmon Anglers Association,
Broadleas,
Co. Kildare.
21st March 2011

File: PMD 03.2
Ref:110321 let

Re: Ballymore Eustace WWTP _ Waste Water Discharge Licence (WWDL) issued by EPA  dated 17th February 2011

Dear Mr. Deegan,
I refer to your letter to Mr. Tom Leahy, dated 28th. February 2011, in relation to the above matter. Mr. Leahy is on leave at present and I am responding on his behalf. I apologise for the delay in replying.
I have asked Mr. Ray Earle, Eastern River Basin Project Coordinator to report to me in relation to the points made in your letter and, accordingly, respond as follows:
1. Kildare County Council and WWTP.
• The existing Wastewater Treatment Plant (WWTP) at Ballymore Eustace serves a very small population with P.E. <500. The Plant provides Primary Treatment only and discharges just downstream of Ballymore Eustace Bridge (see maps attached).
• The old plant will be decommissioned when the new WWTP is built. All design has been completed on the new plant which will be located approx. 1km downstream of existing WWTP. The new plant details are included in the Department of the Environment, Heritage and Local Governments Water Services Investment Programme 2010 to 2012 (WSIP) and initially included since 2005. Funding is the critical issue.
• The two bullet points above are strictly a matter for Kildare County Council to address in conjunction with DEHLG or EPA. The relevant personnel in Kildare Water Services Section are John McGowan SE, John O’Neill SEE and Darren Hughes, Area Engineer working in conjunction with Mr. Joe Boland, DOS.
•  Kildare County Council acknowledges that there is evidence of sewage fungus in the water. However, KCC is satisfied that, based on testing carried out by the Mobile Monitoring Unit of the ERBD, the discharge has no significant impact on the receiving waters.
•  Other discharges in the area include Blessington WWTP with a long pipeline
discharging to Golden Falls and the entire Upper Liffey was studied by the Mobile
Monitoring Unit of the ERBD and a report was published in 2009 in conjunction with the County Councils of Kildare, South Dublin and Wicklow and Dublin City Council.
This Report is available if required.
2. Receiving Waters.
•  The Water body receiving the discharge has been addressed by all relevant
authorities in the ERBD River Basin Management Plan (RBMP) which was adopted
with Ministerial Comments on 6th July 2010 and with associated Programme of
Measures, and SEA/AA Statement. A statutory Public Consultation phase lasting 6 months resulted in numerous submission on the Draft Plan including a submission from the Ballymore Eustace Trout and Salmon Angler’s Association, prior to the plan being adopted as a reserved function by each of the twelve Local Authorities in the ERBD having considered all the submissions at Strategic Policy Committed, Advisory Council and at full Council level.
•  The 6 year 1st  cycle plan as adopted included Version 25 of the EPA status/classification and the EPA details of the receiving water are as follows:

Waterbody name:   EW_Liffey168_Liffey1.
Code:    EA_09_1870_1
Status:    Moderate (EPA V25)
Extended Deadline:   2021 (to reach good status)

• There are two 2 no. EPA Q-value (Macroinvertebate) sites in the vicinity of the Ballymore Eustace WWTP discharges.
a) Ballymore Eustace Bridge -100m u/s – Q3 – 4 (2010)
b) Kimmeens – approx 1km d/s – Q4 (2010)
•  Accordingly, the water quality is actually at a better quality from a Q-value point of view downstream and a Q4 suggests that the receiving waters at this point are very healthy.
3. Legislation.
•  The legislation requires that all discharges must be reviewed under the European
Communities Environmental Objectives (Surface Water) Regulations, 2009 (S.I. No. 272 of 2009) by the end of 2010, and Local Authorities have already begun this process.
•  The ERBD Office is Co-ordinating this work and assisting all twelve constituent Local Authorities via training that is being provided in the new methodology by Consultant Mott MacDonald under the auspices of the WSNTG and also via the use of the electronic River Basin Management System to capture all the relevant data spatially and in tabular form.
• Accordingly the 95 percentile concentrations upstream of the WWTP cited for BOD,
Orthophospate and Ammonia are scheduled to be reviewed under the new legislation and using the new “Assimilation Capacity” methodology imminently. The new methodology takes account of upstream and downstream waterbodies.
• Wicklow County Council are responsible for any WWTP associated with Kilbride,
Lacken, Ballynockan and Valleymount which are located some distance from the Ballymore Eustace WWTP.
4. Role of the ERBD Office.
• The ERBD Office is engaged in meeting with each of the 12 no. constituent Local
Authorities at least three times per year to record progress on the implementation of the RBMP and the Programme of Measures via the RBMS where all progress data, measures and actions are captured and compared with the target objectives.
•  Ultimately it is a matter for Kildare County Council in the first instance to address issues relating to Ballymore Eustace WWTP. Enforcement is also a matter for LAS and EPA. However the ERBD Office will continue to co-ordinate reporting and performance which will highlight the priorities for funding and progressing the detailed measures / actions adopted where any breach is likely. The requirement to deliver on these measures / actions is now a statutory requirement by virtue of the adoption by the Councils of the RBMP and associated Programme of Measures.
• The Upper Liffey Report by the ERBD Office and Consultant CDM published in December 2009 concluded that there was no significant impact on waters arising from the small urban/village centres of Kilbride, Lacken, Ballynockan and Valleymount. Notwithstanding this finding, Wicklow County Council included a Blessington Lakes Sewerage Scheme (to provide treatment and collection system to the villages surrounding Pollaphuca reservoir) in the 2009 Needs Assessment submitted to the Department of Environment, Heritage and Local Government. Unfortunately the Department did not include this scheme in the 2010-2012 Water Services Investment Programme. As such Wicklow County Council is not in a position to advance such a scheme at this time.
If you have any queries in relation to any of the above matters, please do not hesitate to contact Mr. Ray Earle, ERBD Coordinator, at 087-8207905
Yours sincerely,
Adrian Conway,
A/Executive Manager (Engineering).
c.c Ray Earle

Reply from

Energy International
Oibriochtai Giniuna    Generation Operations
Staisiun Giniuna Ard na Croise   Ardnacrusha
Caislean an Chalaidh    Generating Station
Luimneach     Castlebank
Co. an Chlair     Limerick
Co. Clare

The Honorary Treasurer,
Ballymore Eustace Trout & Salmon Angler’s Association,
Broadleas,
Ballymore Eustace,
Co. Kildare.
April 10th 2011

Dear Mr. Deegan,
Your letter of the 28th February to our Chief Executive, Padraig McManus, refers. It has been passed onto me for my attention.
In relation to the Waster Water License, dated 17th February 2011, issued to Kildare County Council, it is not appropriate for ESB to comment as it is not the responsible body for these matters.
ESB’s role on the upper Liffey catchment is set out in the Liffey Reservoir Act 1936 and relates to the safe management of water flows on the Liffey. In this regards, ESB interacts and co-operates with all the statutory bodies which operate in the Liffey catchment. ESB carries out its operations in accordance with the highest international environmental standards.
I trust that this letter clarifies ESB role on the Liffey.
Yours Sincerely,
Senan Colleran
Hydro Manager
Generation Operations
ESB Energy International

 

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
25th April 2012
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate, McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir/Madam,

On behalf of the above Association I wish to complain in the strongest possible terms about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. This scum like algae on the surface is seriously reducing the recreational and aesthetic value of the Liffey and is totally unacceptable. It is impossible now for anglers to fly fish the Liffey at Ballymore Eustace without getting their lines and flies covered in algae. Also, since there is a filamentous algae covering the gravels there is a danger that this is harming the aquatic invertebrates, flora and fauna of the Liffey and this needs to be investigated.

The Association reported a similar algae growth to the Office of Environmental Enforcement by letter dated 13th April 2009 and again by letter dated 19th April 2010. In the mistaken belief that something was being done to remedy the situation we did not report the matter in 2011. However, no action to remedy the pollution has to our knowledge been taken by the EPA, Wicklow or Kildare County Councils.  This is totally unacceptable.

Since the algae is present upstream and downstream of Kildare County Council’s overloaded sewage treatment plant discharge at Ballymore Eustace, the Association believes that the source of the pollution is nutrients from the Blessington Waste Water Treatment Plant. While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.  The ESB control the water flow through the Lake and Licensed the discharge.

Wicklow County Council should never have been allowed discharge effluent from Blessington WWTP into Golden Falls Lake where a minimum dilution was not guaranteed and this injustice must be rectified. The Association requests the Office of Environmental Enforcement, Environmental Protection Agency to take immediate action to rid the Liffey of this horrible pollution.  Indeed it is time the EPA took a much firmer stance on all the sources of pollution to the Liffey at Ballymore Eustace.

Yours sincerely,

___________________________
Thomas Deegan
Honorary Treasurer
Copy:  Mr. Eddie Sheehy, Manager, Wicklow County Council
Mr. Michael Malone, Manager, Kildare County Council
Mr. Pat O’Doherty Chief Executive, Electricity Supply Board.
Mr. William Walsh, Inland Fisheries Ireland.

WICKLOW COUNTY COUNCIL
Water & Environmental Services
Aras An Chontae
Cill Mhantain
Water & Environmental Services
(0404) 20236
Waste Management (0404)20127 Fax No: (0404) 67792
E-Mail: env@wicklowcoco.ie  Web: www.wicklow.ie
Our Ref:    BD/AW
23rd May, 2012.

Mr. Thomas Deegan,
Honorary Treasurer,
Ballymore Eustace Trout & Salmon Anglers’ Association,
Broadleas,
Ballymore Eustace,
CO. KILDARE.

Re: Blessington Waste Water Treatment Plant.
Dear Mr. Deegan,
I wish to acknowledge receipt of your letter dated 25th April, 2012.
I wish to refer to this Council’s correspondence to you in February/March 2011. I made available to you details of the Council’s testing results for the Blessington Waste Water Treatment Plant for the years 2008 to 2010. Furthermore, you were informed of the Council’s proposals for monitoring in 2011. Wicklow County
Council did not receive any queries with regard to the content of the information submitted to the Anglers’ Association.

In light of these circumstances, your correspondence suggests a non technical approach to denigrate the reputation of Wicklow County Council and performance of the Blessington Waste Water Treatment Plant without the submission of any evidence that this is the case.
The Treatment Plant is operated by Veolia Ireland Limited on behalf of Wicklow County Council and discharges to the Golden Fall Lake which is downstream of Pollaphuca Dam and upstream of Ballymore Eustace.

It was upgraded in 2007 and includes the provision of phosphate removal facilities as part of a secondary treatment process. Thus the reduced concentration of phosphate (a nutrient) in the effluent means it is unlikely to promote growth of algae in the Goldenfalls Lake. The quality of the discharge from the Treatment Plant is monitored frequently and results indicate that the plant is operating within its design parameters. The discharge is also meeting the requirements stipulated by the E.S.B. licence.
For your information, I am attaching the monitoring results for the Golden Falls Lake as follows:-
• (a) Table 1 (enclosed) contains monitoring data for three stations (l) upstream of the Golden Falls, (2) Goldenfall Mid Lake and (3) downstream of the Golden Falls for the years 2008 to 2011. The data records the annual mean levels for Chlorophyll, Total Phosphorous, Ammonia, Faecal Conforms and Total Coliforms. The results show compliance with the relevant Water Framework Directive physiochemical criteria.
• (b) Table 2 (enclosed) records detailed monitoring data for 2011 for the same three monitoring points. The results show compliance with the relevant Water Framework Directive physiochemical criteria.
• (c) Table 3 (enclosed) records relevant monitoring data for January, February and March 2012. The results would not suggest that the algal problem is caused by the discharge to the lake.
• (d) The Eastern River Basin District report titled “Programme of Measures Pilot Study – Upper Liffey” (December 2009) addressed the impact of discharges on Golden Falls lake (pages 45-53) and concludes that there are no significant adverse impacts on the lake.  On page 45 the report states
“historically, Blessington Waste Water Treatment Plant has displayed elevated concentrations of nutrients. However, recent water quality data has shown that water quality in the area was found to be within standard limits.”
• CMD- Smith who have sampled Golden Falls on behalf of Wicklow  County Council since February 2011 has not seen any algal bloom in the lake since that time and has not noticed any algal growth below the dam while taking the downstream sample.
Wicklow County Council carries out monitoring of the Golden Falls Lake but does not monitor or investigate downstream of the lake, which is in County Kildare. Therefore, Wicklow County Council would not be aware of any other discharges to the River Liffey downstream of the lake and Ballymore Eustace.
The results as set out above do not suggest that the Blessington discharge to be the cause of the algae bloom.                             .
The last paragraph of your letter, while I note is for a broader audience is not applicable to the Blessington Waste Water Treatment Plant at this time. If the Anglers Association can demonstrate that Wicklow County Council is the source of pollution, I would ask them to present the evidence on the basis of their examination of the results provided.
If there are concerns, the Council’s Technical Staff are at all times willing to discuss the issues. The County Council maintains close contact with our colleagues in Kildare County Council and have met with them and discussed the situation on an ongoing basis.
I trust this information allows you to consider the matter further and if you have any queries, please do not hesitate to contact the undersigned.
Yours faithfully,
BRYAN DOYLE
DIRECTOR OF SERVICES,
WATER & ENVIRONMENTAL SERVICES.

ENCL.

BALLYMORE EUSTACE TROUT AND SALMON ANGLERS’ ASSOCIATION

Broadleas,
Ballymore Eustace,
Co. Kildare.
29th May 2012
Mr. Bryan Doyle,
Director of Services,
Water and Environmental Services,
Wicklow County Council,
County Buildings,
Wicklow.

Re: Blessington Waste Water Treatment Plant Discharge to Golden Falls Lake.

Dear Mr. Doyle,

Thank you for your letter dated 23rd May 2012 and enclosures.

It is most disappointing when professional people have to resort to personal attacks as their only line of defence. I have no interest in trying to denigrate Wicklow County Council. My only concern is for the water quality of the Liffey at Ballymore Eustace, Co. Kildare downstream of Golden Falls Lake/Reservoir. As stated in the Eastern River Basin District report titled “Programme of Measures Pilot Study – Upper Liffey” which you yourself quoted “historically, Blessington Waste Water Treatment Plant has displayed elevated concentrations of nutrients.” Also, the EPA has in the past placed Golden Falls Lake in the Hypertropic Category i.e. a very high level of pollution. So, please get off you high horse and maybe address you criticisms at the man in the mirror. Monitoring alone never solved any problems as results have to be assessed and, if necessary, acted upon. I ask that Wicklow County Council stop acting ostrich like with regard to the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake and work with the Association in trying to solve a perennial problem of algae growth destroying the aesthetic and recreational value of the Liffey at Ballymore Eustace.

When granting a WWDL to Kildare County Council for the proposed new WWTP at Ballymore Eustace, the EPA Inspector in her report dated 2nd February 2011 stated
“The results of the assimilative capacity calculations are summarised as follows:

(i) Biochemical Oxygen Demand
At the design emission limit value (25 mg/l), there is no assimilative capacity in the
receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of2009 before consideration of the WWTP discharge contribution.

However, the calculations in Table 3.0 indicate, for a notionally clean river, at an
emission limit value of 25 mg/l BOD at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for BOD, based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is only 0.13 mg/l BOD. Therefore, the effluent design standard of 25 mg/l BOD has been set as the emission limit value from 31 December 2012 in the RL.

(ii) Phosphorus
There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
For a notionally clean river, at an emission limit value of 1 mg/l at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for orthophosphate based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.005 mg/l orthophosphate. The RL sets an emission limit value of 2 mg/l for total phosphorus (the effluent design standard) and an emission limit value of 1 mg/l for orthophosphate from 3 1 December 2012.
Condition 5 of the RL requires the licensee to continually reduce total phosphorus
emissions in the discharge.

(iii) Ammonia
There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.
For a notionally clean river and an emission limit value of 5 mg/l at 2,000 p.e., there
would be adequate assimilative capacity in the receiving water for ammonia based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.026 mg/l of ammonia. Accordingly, the RL set an emission limit value of 5 mg/l for ammonia from 31 December 2012 to ensure compliance with S.I. No. 272 of 2009.
Condition 5.1 of the RL requires the licensee to continually reduce ammonia emissions

Table 3.0 above highlights that other measures need to be put in place to reduce high
background concentrations of BOD, orthophosphate and ammonia in the receiving waters upstream of the WWTP if the River Liffey is to achieve good stutus under the Water Framework Directive. It is not the role of the Wastewater Discharge Licence to address these other pollutant sources, it can only address the waste water discharges.”

I am aware that the above is based on background water quality data from January 2007 to February 2009 and that the Blessington WWTP was upgraded in 2007.

Because the problem shows up in County Kildare, maybe Wicklow County Council feels it doesn’t have to address “these other pollutant sources”, but the Association has no intention of letting matters rest until the Liffey at Ballymore Eustace is as near as is possible to pollution free.
Looking at the monitoring results for Golden Falls Lake one thing sticks out like a sore thumb. There could be up to a tenfold increase in the ammonia concentration in Golden Falls Lake and the downstream samples in spring each year which coincides with the algae growth in the River Liffey.

Perhaps you can use your chemical knowledge and technical approach to convince me that this cannot be attributed to Blessington WWTP discharge into Golden Falls Lake and that it is merely a coincidence that it coincides with the algae growth in the River Liffey at Ballymore Eustace each year. Even better, maybe something can be done to reduce the ammonia concentrations in the Golden Falls Lake.

My understanding is that for ammonia the EQS for Surface Waters is 0.02 mg/l. The limit for the non-ionised form of ammonia under the Freshwater Fish Directive is 0.025 mg/l while the limit for non-ionised ammonia under the Salmonid Waters Regulations is 0.02 mg/l.

I include below a graph of the ammonia results from Golden Falls to illustrate and highlight the situation.

Yours sincerely,

_______________________________
Thomas Deegan
Honorary Treasurer

AmmoniaGFallsfeb11mar12

(Why is the lower level of detection set 0.03 mg/l ?)

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Administration,                                         Ballymore Eustace,
Environmental Licensing Programme,     Co. Kildare.
Office of Climate, Licensing & Resource Use,    30th May 2012
Environmental Protection Agency,
Headquarters,
P.O. Box 3000,
Johnstown Castle Estate.
Co. Wexford.

Waste Waster Discharge Licence Application Register No: D0063-01

Dear Sir/Madam,

The above Association recently received a copy of the monitoring results of Golden Falls Lake from Wicklow County Council for the period February 2011 – March 2012. It is obvious from the results that there is an increase in the concentration of ammonia in the Golden Falls Lake and downstream samples in the Spring of the year which coincides with the perennial problem of algae growth in the Liffey.

I have included a graph (with notes) to illustrate the occurrence.

The above Association respectfully requests the EPA to take this into account when processing the above Waste Water Discharge Licence Application.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

AmmoniaGFallsfeb11mar12
WICKLOW COUNTY COUNCIL
Water & Environmental Services

BD/AW
14th June, 2012.
Mr. Thomas Deegan,
Honorary Treasurer,
Ballymore Eustace Trout & Salmon
Anglers’ Association,
Broadleas,
Ballymore Eustace,
CO.KILDARE.
Re: Blessington Waste Water Treatment Plant

Dear Mr. Deegan,

I wish to acknowledge receipt of your letter dated 29th May, 2012  (I did also receive email in relation to this matter). The content of the correspondence is noted.
Wicklow County Council is anxious to move this debate forward. Part of the reasoning in your responses has been to detail what has happened in the past prior to the Waste Water Treatment Plant being constructed in Blessington. Your Group query the decision of the E.S.B. back in 1985 to give a Licence to discharge to the
Golden Falls. The County Council is adamant that things have progressed since that time including the provision of phosphate reduction treatment at the Blessington Wastewater Treatment Plant. This is of significant benefit because phosphate is a
known contributor to the growth of aquatic plants and algae in inland waters.
I wish to address the technical nature of your argument outlined in your correspondence as follows.
1. The data used by’ the EPA in the Assimilative Capacity Report referenced by the Anglers’ Association was from urban waste water returns (upstream and downstream of the Ballymore Waste Water Treatment Discharge). It is the Council’s understanding that this data was generated from staff in the local Waste Water Treatment Plant using basic equipment. The council would feel that this data should not have been used by the E.P.A. in their report considering that there were existing National Monitoring Stations upstream and downstream for which reliable data is available. The data from these
stations and the results are far more realistic (see attachment) and compare well with the County Council data below the Golden Falls dam for the same period. There were a number of outlying results which caused averages to elevate but results from 2007-2009 confirmed good physiochemical status at
Ballymore Bridge.
2. The Council notes that the EPA. were quoting 95% results (highest 5% of results) in their report and not average results i.e. extreme rather the normal situation. Even accounting for this the EPA report figures are multiples of ten times higher than our results for the same period (see comparison of dataattached).
3. The County Council is stating that the complaint would appear to be unfounded based on the National River Monitoring Data and Wicklow County Council Golden Falls Monitoring Data for die period 2007-2009 and also based on current data from 2011. The data shows from Golden Falls monitoring and Kildare’s National River Monitoring that there is a
assimilative in capacity for the current set up at Blessington. The ammonia concentrations are close to the limits and peaks have been experienced in the early part of this year.  With regard to the limit for (un-ionised) ammonia. I wish to point out the Council does not analyse unionised ammonia. The Council is not required to do so under the Water Framework Directive. The Council is measuring and quoting the sum of both forms of ammonia (un-ionised and ionised) referred to as total ammoniacal nitrogen by the EPA. The limits for Good Status in the S.I. 272/2009 for total ammoniacal nitrogen are
average = 0.065mg/l n N, 95% = 0.14mg/l n N. Statistical data supplied shows the station monitored by Wicklow, County Council downstream of Golden Falls is compliant with the limits as far as 2011 (data attached).

I agree with the approach of the Anglers in seeking the best possible treatment being provided to maintain river quality in the River Liffey. Wicklow County Council is fully committed with our partner Veolia to operate the Blessington Wicklow Treatment Plant to the highest standard.
Yours faithfully,
BRYAN DOYLE,
DIRECTOR OF SERVICES,
WATER/& ENVIRONMENTAL SERVICES.

Encl.

 

Another letter from the Association to the EPA
Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
25th March 2013
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate, McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir/Madam,

Once again, on behalf of the above Association I wish to complain in the strongest possible terms about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. This scum like algae on the surface is seriously reducing the recreational and aesthetic value of the Liffey and is totally unacceptable. It is impossible now for anglers to fly fish the Liffey at Ballymore Eustace without getting their lines and flies covered in algae. Also, since there is a filamentous algae covering the gravels there is a danger that this is harming the spawning potential, the aquatic invertebrates, flora and fauna of the Liffey and this needs to be investigated.

The Association reported a similar algae growth to the Office of Environmental Enforcement by letter dated 13th April 2009 and again by letter dated 19th April 2010. In the mistaken belief that something was being done to remedy the situation we did not report the matter in 2011. We reported the matter again by letter dated 25th April 2012 and apart from the Office of Environmental Enforcement passing the buck to its WWDA section, no action to remedy the pollution has to our knowledge been taken by the EPA, Wicklow or Kildare County Councils.  This is totally unacceptable.

Analytical results received from Wicklow County Council for 2011 and early 2012 we believe show a relationship between the rising ammonia concentrations in Golden Falls Lake, the Liffey downstream and the algae growth in the Liffey at Ballymore Eustace. No rise in ammonia levels are recorded for Poulaphouca Reservoir upstream of Golden Falls Lake which indicates that the problem starts in Golden Falls Lake. (See graph below) A WWDL was granted by the EPA to Wicklow County Council on the 12th June 2012 but this did not address the problem.

Since the algae is present upstream and downstream of Kildare County Council’s overloaded sewage treatment plant discharge at Ballymore Eustace which is presently being replaced with a new WWTP, the Association believes that the source of the pollution is nutrients from the Blessington Waste Water Treatment Plant. While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.  The ESB control the water flow through the Lake and initially licensed the discharge into Golden Falls Lake.

Wicklow County Council should never have been allowed discharge effluent from Blessington WWTP into Golden Falls Lake where a minimum dilution was not guaranteed but we must now live with this injustice. However, we don’t have to live with the pollution of the Liffey and the Association, once again, requests the Office of Environmental Enforcement, Environmental Protection Agency, in conjunction with the other relevant authorities, to carry out a thorough investigation into the effects of the stop/start water flows into Golden Falls Lake and past the Blessington WWTP discharge point, on the ammonia/pollution levels in the Lake. And, we also ask the EPA to take immediate action to rid the Liffey downstream of this horrible pollution.

 

AmmoniaGFallsfeb11mar12
(Why is the lower level of detection set 0.03 mg/l ?)
Note no rise in low level ammonia concentration in the Poulaphouca Reservoir upstream sample

Yours sincerely,

___________________________
Thomas Deegan
Honorary Treasurer

 

Copy:  Mr. Bryan Doyle, Director of Services, Wicklow County Council
Mr. Joe Boland, Director of Services, Kildare County Council
Mr. William Walsh, Inland Fisheries Ireland, Blackrock.

epa
Office of Environmental Enforcement

Mr. Thomas Deegan
Honorary Secretary
Ballymore Eustace Trout and Salmon Anglos Association
Broadleas
Ballymore Eustace
Co. Kildare

Our ref: D0063-01/D0063-01 27032013 Response to Complaint.docx

10/04/2013

Dear Mr. Deegan,
I refer to your correspondance dated 25th  March 2013, received by the Agency on 27th March 2013, made on behalf of the Ballymore Eustace Trout and Salmon Anglers’ Association, in relation to Wicklow County Council’s waste water treatment plant (WWTP) at Blessington. As you may be aware this WWTP holds a waste water discharge licence, reg. no. D0063-01, which was issued by the Environmental ProtectionAgency (EPA) on 12th June 2012.
I note your concern in relation to this WWTP and I am to advise you that the Office of Environmental Enforcement (OEE) has opened a Compliance Investigation (ref. no.CI000058) against the Blessington licence reg. no. D0063-01. The current treatment plant at Blessington requires additional infrastructure to meet me Ammonia emission limit value (ELV) of 5mg/l as stipulated in their EPA licence reg. no. D0063-01.CI00058 was initiated in relation to the Ammonia ELV breaches at the facility and the requirement for an upgrade at me WWTP to be completed.
Wicklow County Council have submitted a formal application to the Department of Environment, Community and Local Government (DECLG) ‘ for their approval and funding for the proposed upgrade of the existing wastewater treatment plant at Blessington. The proposed upgrade is to provide sufficient treatment for a population equivalent of 9,500, while meeting the emission limit values stated in the licence. A progress report is due to be submitted to the Agency on 28/06/2013.
In relation to your specific complaint on Ammonia, we have forwarded it to Wicklow County Council requesting them to assess if the discharge is having an impact on Golden Falls Lake. Wicklow County Council have been requested to respond to the EPA plus yourselves in relation to your complaint.
If you require any further assistance or information in relation to this matter please don’t hesitate to contact a member of Team B in OEE Wexford and the representative in charge of this plant in Wicklow County Council. Please quote the above reference in future correspondence in relation to this matter.
Yours sincerely

Inspector
Office of Environmental Enforcement
Team B- Wexford

WICKLOW COUNTY COUNCIL
Water & Environmental Services
County Buildings, Wicklow
Water & Environmental Services
(0404)20236

OEE Water (Wexford)
Office of Environmental Enforcement.
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
CO.Wexford.
24th April 2013

Dear Sir/Madam,
I refer to letter dated 25th March 2013 from the Ballymore Eustace Trout and Salmon Anglers’ Association to the Environmental Protection Agency.
The letter complains of algae scum in the river Liffey at Ballymore Eustace, Co. Kildare and states that the likely cause is the discharge from the Blessington waste water treatment plant.
Blessington wastewater treatment plant is operated by Veolia Water Ireland on behalf of Wicklow County Council and discharges to the Golden Falls Lake, which is downstream of Pollaphuca Dam and upstream of Ballymore Eustace.
The treatment plant was upgraded in 2007 in order to meet all of the wastewater treatment requirements in force at that time. The upgrade works included the provision of phosphate removal facilities.
The discharge from the treatment plant is monitored frequently and the results indicate that the plant is operating within the parameters it was designed to do.
The Waste Water Discharge (Authorisation) Regulations 2007 require that all discharges from the wastewater treatment plants be licenced by the Environmental Protection Agency. The Blessington plant received its licence on 12th June 2012.
The licence requires that the discharges from the plant must not breach the Emission Limit Values for certain parameters. Blessington has no problem in complying with this for most of the parameters – with the exception of ammonia.
The treatment plant was not designed to comply with the Emission Limit Value set for ammonia. In order to achieve compliance it will be necessary to carry out a costly upgrade of the treatment facilities.
Wicklow County Council submitted a formal application to Department of the Environment Community and Local Government earlier in 2013 seeking their approval and funding of the proposed upgrade works at Blessington under the Department’s Water Services Investment Programme. The Council awaits the Department’s decision.

Downstream Monitoring Results
Monitoring is carried out to the Golden Falls waters, which receives the Blessington discharge.
The most recent results (up to March 2013) are enclosed in APPENDIX A.

Table 1 shows the results for the mid-point of the Golden Falls lake, which is
downstream of the Blessington discharge.
Table 2 shows the results for a location, which is further downstream at a point downstream of Golden Falls dam.

The results show that the quality of the water at both locations is at GOOD STATUS.

It is recognized that an elevated concentration of phosphorus (and not ammonia) is the recognised critical factor in the promotion of aquatic plant growth such as algae in freshwater.
The Appendix A results demonstrates that phosphorus concentrations are not elevated in the receiving waters.

The monitoring results do not suggest the Blessington discharge to be the cause of the algae scum.

For your information I am also attaching, herewith-

• Letter of 14th June, 2012 to Mr. Thomas Deegan (copied to EPA)
• Letter of 23rd May, 2012 to Mr. Brendan Kissane, OEE.
• Letter of 23rd May, 2012 to Mr. Thomas Deegan.

Should you require any further information please do not hesitate to contact Mr. Larry Wolahan, Senior Executive Engineer, Water Services.
Yours sincerely,

Bryan Doyle
Director of Services,

cc
Mr. Thomas Deegan,
Broadleas,
Ballymore Eustace,
Co. Kildare

APPENDIX A
Sampled Date Ammonia (mg/1- N) BOD (mg/1) Phosphorus (React) (mg/l-P) Total Phosphorus (mg/1 – P) Chlorophyll a (mg/m3) pH Surface 02 %Sat.

25/01/2012  0.07      0.02  0.5  7.6  98.8
22/02/2012  0.1      0.02  1.9  7.7  100.1
21/03/2012  0.17  1  0.015  0.02  5.6  8  102.3
11/04/2012  0.13  1  0.015  0.01  2.3  8.2  100.2
23/05/2012  0.015  1  0.015  0.01  3.6  7.9  103.9
27/06/2012  0.03  1  0.015  0.02  1.6  7.6  95.4
18/07/2012  0.015  1  0.015  0.02  0.5  7.7  85.3
28/08/2012  0.015  1  0.015  0.02  0.8  7.8  86
19/09/2012  0.015  1  0.015  0.01  0.9  7.7  98.4
24/10/2012  0.015  0.5  0.015  0.02  0.9  7.8  90.2
21/11/2012           0.015 0.5  0.015  0.02  0.7  7.8  93.3
12/12/2012           0.03 0.5  0.015  0.02 0.8 7.6 95.9
30/01/2013  0.015  0.5  0.015  0.02  0.8  8.0  102.9
20/02/2013  0.04  0.5  0.015  0.01  0.8  7.8  96.4
20/03/2013  0.23  0.5  0.015  0.02  1.7  7.8  96.9

Average  0.060  0.769  0.015  0.018  1.6  7.8  96.4
95% ie  0.188  1.000  0.015  0.020  4.4  8.1  103.2
Table I: Goldenfalls Lake (mid-lake sample – 120210) at 293550 Easting, 208500
Northing
Sampled Date Ammonia (mg/1- N) BOD (mg/1) Phosphorus (React) (mg/1 – P) Total Phosphorus (mg/1 – P) Chlorophyll a (mg/m3) pH Surface 02 % Sat.
25/01/2012  0.07      0.02  0.3  7.7  99.1
22/02/2012  0.08      0.02  0.5  7.7  100.9
2V03/2012  0.1  l  0.015  0.01  4.3  7.9  100.2
11/04/2012  0.1  1  0.015  0.01  2.5  7.9  98.7
23/05/2012  0.05  l  0.015  0.01  0.7  8  99.9
27/06/2012  0.03  l  0.015  0.04  0.3  7.5  91.2
18/07/2012  0.015  l  0.015  0.02  0.1  7.7  88.4
28/08/2013  0.03  l  0.015  0.02  0.8  7.7  94.4
24/10/2012  0.015  0.5  0.015  0.02  0.9  7.7  89.4
21/11/2012  0.015  0.5  0.015  0.01  0.7  7.8  97.5
12/12/2012  0.04  0.5  0.015  0.02  0.1  7.6  95.4
30/01/2013  0.015  0.5  0.015  0.02  0.3  8.0  103.5
20/02/2013  0.015  0.5  0.015  0.02  0.9  7.8  97.3
20/03/2013  0.28  0.5  0.015  0.02  1.9  7.8  98.4

Average  0.058  0.769  0.015  0.018  0.7  7.7  95.9
95% ile  0.154  1.000  0.015  0.029  3.2  7.9  101.7
Table 2: Downstream (Goldenfalls Dam sample – 120220) at 292920 Easting,
208990 Northing

 

(more…)

Tidy Towns Competition 2013

Adjudication Report

Centre:    Ballymore Eustace                   Ref:    357

County:    Kildare                                       Mark:     290

Category:     B                                             Date(s):     03/07/2013

                                                                Maximum    Mark        Mark
                                                                Mark         Awarded  Awarded
                                                                                    2012           2013

Overall Development Approach               50                38               39
The Built Environment                              50                37               38
Landscaping                                              50                39               40
Wildlife and Natural Amenities                50                36               37
Litter Control                                           50                 35               36
Sustainable Waste And Resource Mgt.     20                 10               11
Tidiness                                                   30                 17               17
Residential Areas                                     40                 32               32
Roads, Streets and Back Areas               50                  32              32
General Impression                                  10                    8                8

TOTAL MARK                                    400                284            290

Overall Development Approach:
Ballymore Eustace is welcomed to the TidyTowns Competition for 2013.  Thank you for your entry, map and copy of your new three year plan and supporting documentation which was very helpful to the adjudicator.Your group of six people as per photograph (looking very happy together with a core of volunteers) are working well with Kildare County Council, Fas and other relevant agencies that supply you with support and assistance. 
You communicate well with the community through newspapers and media.  Try using social media, texting and email as it will save you time.  The local businesses and community play a necessary part in the committees work and their support and sponsorship is a vital ingredient to your success.  Thank you for your positive
feedback on the competition and the importance of the TidyTowns competition to the village.  Increasing membership to the committee can be a difficult task with many groups, but once continuous support from volunteers and the community is on-going the group will succeed.  Wishing you well with your calendar of events
and in particular the forthcoming gathering, a reunion of old school pupils is wished success.

The Built Environment:
The Built Environment of the village is made up of a mix of old and new buildings all blending well to make an attractive streetscape.  Your work on unoccupied buildings has made the streetscape neat and tidy and much more presentable.  Market square is an important part of the town structure featuring a nice water feature
and is well landscaped.  St. Johns Church of Ireland and graveyard looked well.  The Thatch Restaurant with nice window boxes looked bright and welcoming.  Other pleasant buildings included the Village Store, Health Centre and the Credit Union.  The Church and Montessori School beside were well presented.  The Parish Centre another important facility for the community together with the School, all was well landscaped, neat and tidy.  The village pump which is an important feature of most towns and villages also adds splendour to the streetscape.

Landscaping:
The Landscaping throughout the village at Market Square with the water feature and landscaping of the Boat at the Liffey Bridge looked superb.  The Kilcullen Naas Road has a nice green area with pleasant bedding on the corner; wild flowers in this area were also admired.  Barrack Street is a particularly nice street with planting and trees.  The many window boxes and hanging baskets, the permanent and summer bedding plants which are part of the village landscape were noted and admired.  Looking at the photographs submitted with your entry the village looks very colourful during Autumn/Winter.  This type of planting is encouraged by the TidyTowns together with the planting of trees and hedging.  Well done to the winner of the best small garden in your competition which is situated at St. Brigids Park.

Wildlife and Natural Amenities:
The walk along the river is a lovely amenity for the community.  Entering the walk from Assumpta Terrace the adjudicator had a pleasurable walk along the river enjoying the nature of the river and the surrounds.  The proposed new wildlife interpretive signage for the river walk would add greatly to this lovely amenity.  The
wildflowers were also noted as was the wildlife on the river.  This is also an excellent facility for Scoil Mhuire and do include the schools in any future heritage or nature trails been developed.

Litter Control:
Litter in an on-going problem and hard to combat.  Creating awareness in the community and working with the schools is the right approach.  Conducting clean-ups in spring which include the community and school are important and also regular litter picks during the summer gets everyone involved.  Some groups have an “Adopt a road” with volunteers responsible for that road and it is working well.  The ‘clean-up after your dog’ signs were also noted.  On day of adjudication very little litter was noticed, with just a small amount in the square.  Well done on your work in this category.

Sustainable Waste And Resource Management:
Well done to the school on their achievements in the Green Schools Initiative.  The community are working closely with the school in reducing waste and this can help create awareness on the whole issue of waste.  The results of the survey should indicate areas where waste could be reduced.  The TidyTowns handbook offers useful information in this area.  Food is one of the areas where waste could be reduced.  Resource management in the areas of water, energy and transport can bring savings to the community.  Continue the work you are doing in this category concentrating on the top of the pyramid and look at ways of reducing.

Tidiness:
Some area of untidiness was noticed, nothing too major.  Weed growth at kerbs and car park gives an untidy look.  In the square there was a sliding door which needs painting.  Across from Barrack Street railing or barrier needs painting, also 50km sign needs attention.  The bottle banks were reasonably tidy.  The work at Ball Alley entrance and Old Mill piers was noted.  Well done also on work at Assumpta Terrace, paling and hedging looks neat and tidy.  Road surfaces on the Baltinglass Road and the Church Road were uneven.

Residential Areas:
The many areas of housing visited were admired.  Liffey Heights /Liffey Court were all well maintained as was Assumpta Terrace which was well presented.  There were some lovely houses with nice window boxes and hanging baskets such as Hillcrest.  Barrack Street had lovely well maintained houses with nice landscaping. 
Rose Cottage and the house with the blue door looked well.  There was a lovely mix of single storey and two storey houses all adding their own uniqueness to the streetscape of the village.  Well done to all the residents for their work in this category, it shows they have pride in the village.

Roads, Streets and Back Areas:
As stated under tidiness there are some uneven road surfaces.  The resurfacing of Main Street was noted as was the new footpath and pedestrian lights near the school. Approach roads were well presented with neat grass verges.  Kilcullen/Naas Road had some nice bedding and wildflowers.  Nameplate signs for the village need to be put in place on all roads into the village.

General Impression:
Ballymore Eustace was a pleasure to visit and has the potential to progress further in the competition.  Thank you for participating and you are wished continued success.

Tidy Towns Competition 2012

Adjudication Report

Centre:          Ballymore Eustace                            Ref: 357

County:         Kildare                                              Mark 284

Category:      B                                              Date(s) 21/06/2012

                                                                Maximum  Mark        Mark
                                                                Mark         Awarded    Awarded
                                                                                 2011          2012
Overall Development Approach               50            38              38
The Built Environment                             50            36               37
Landscaping                                              50            39               39
Wildlife and Natural Amenities                50            36               36
Litter Control                                            50             34              35
Tidiness                                                     30             17              17
Waste Minimisation                                  20             10              10
Residential Areas                                      40             32              32
Roads, Streets and Back Areas                 50             32              32
General Impression                                   10              8                8

Total Mark                                              400            282            284

Overall Development Approach:
Welcome Ballymore Eustace TidyTowns Group to the 2012 TidyTowns competition. Your entry is very much appreciated.
Your entry form is concise and the additional document that accompanied your entry form made interesting reading. Your current 3 year plan runs until the end of this year so your next 3 year plan will be from 2013 – 2015. If you do any work from the end of this year’s competition in September next then include it as valid for the 2013 competition. Please include a copy of your new 3 year plan with next year’s entry form.
We note that your committee now has 5 members, a small enough number to tackle all of the work you have planned. Your committee meetings are adequate for your needs and we note that you are a sub-committee of the Ballymore Eustace Community Development Association.
The agencies and organisations from which you get support are diverse, which is good.
You use appropriate local media to communicate. Please enclose copies of newsletters, press cuttings, etc. that mention your TidyTowns activities with your entry. These may be taken into account when marks are being decided and will be returned to you when the competition is over.
Your engagement with the school is very good. The pupils can be a very useful resource to your Tidy Towns group.
You are fortunate to have such generous financial supporters. Well done to all of them.
Your events are noted.

The Built Environment:
The repairs to Pinkeen Bridge were seen. Well done. Clearing the roots and improving the walk were also noted. This adjudicator used the steps to get to the walk and thanks you for repairing the handrail.
Maintenance of street furniture, landscaping, etc. is of a high order.
Ballymore Eustace is a very pleasant village and its public buildings and other buildings of note are well presented. The Millennium Garden would grace any village or town and is very well maintained. The Millennium Garden also merits comment in the Tidiness and Roads, Streets and Back Areas categories.
St. John’s C. of I. and cemetery are important attractions, particularly for the 2 High Crosses. All are well presented, neat and tidy. The information board was read with interest. The old stone walls were admired.
The gate was unlocked which was very trusting given the references in your entry to vandalism.
Church of the Immaculate Conception is in a key location in the village. It was well presented, neat, tidy.
The Parish Centre looked well and had 2 raised flower beds adding summer colour. Scoil Mhuire was flying its Green Flag and its grounds were neat, tidy and well maintained. No litter. The Garda Station is well presented. The cottages on Barrack Street are eye catching with hanging baskets and flower pots.

Landscaping:
The iconic landscaping feature is the rowing boat high and dry in its raised flower bed beside the bridge. It has a good floral display as cargo. There is nice landscaping at the Naas/Kilcullen Roads junction. Around the village there were planters with lots of flowers adding summer colour. Landscaping on approach roads will be dealt with in the Roads, Streets and Back Areas category. Your tree planting on the Kilcullen/Mount Cashel road was seen. You have a high maintenance workload which is often overlooked by visitors, and possibly some locals, when they stop to admire your landscaping.

Wildlife and Natural Amenities:
This adjudicator did the River Liffey Walk. The damage caused by such a small stream is awesome. It is an excellent amenity and hopefully it will be restored as soon as possible. Your wildlife flower planting along the walk is commended. The guided nature trail and heritage trail walks with the Scoil Mhuire pupils is also commended.

Litter Control:
The new “Clean up after your dog” and “No dumping” signs were seen. Litter outside shop on Chapel Street.
As mentioned earlier, please enclose with your entry form articles in the newsletter dealing with litter control.
Your clean up sessions and litter patrols are having the desired effect. There was very little litter in evidence in Ballymore Eustace on adjudication day. In your next TidyTowns entry please let us know the frequency of your litter controls. Well done to all involved.

Tidiness:
This adjudicator concurs with the comments made by last year’s adjudicator that the direction signs on the pole at the Millennium Garden be relocated. They are obscured by trees and each other and are an eyesore, detracting from the Millennium Garden, one of the key features in the village.
The Recycling Centre was clean and tidy. Handball Alley was also clean and tidy. No litter. The blue hoarding on Main Street is unfortunate. Unfinished developments are a blight on many towns and villages but are a national problem and not the responsibility of TidyTowns groups. The presence of these unfinished developments do not have an adverse impact on your marks.
Barrack Street – bollards need to be cleaned.
Direction signs at the Poulaphouca approach road junction need to be cleaned.

Waste Minimisation:
Please consult the TidyTowns handbook for advice and tips on this category. The first action point given on the entry form for this category is “Promotion of best practice”. TidyTown groups are expected to be proactive in communicating with their community, both villagers and retailers, the principles of waste minimisation. The waste pyramid used in the entry form to illustrate the relative importance of each option shows that recycling is a less favoured option than minimisation. Minimisation is about reducing the amount of material, including food, that enters Ballymore Eustace and ends up as waste. It also includes reducing consumption of energy, water, etc. Use the parish newsletter and any other communications method available to you. Ask the TidyTowns Unit for the booklet Race against Waste. A useful web site is www.stopfoodwaste.ie.
You published a recycling information sheet please enclose a copy with next year’s entry form as it will be of interest to the adjudicator.
The Household Waste Survey carried out in conjunction with Kildare County Council and Scoil Mhuire pupils was an excellent initiative. Please say in next year’s entry form what action, if any, is being taken as a result of the survey’s findings.

Residential Areas:
Many of the projects you list in this category are more appropriate to other categories and have already been dealt with e.g. River Liffey Walk, damage to Pinkeen Bridge, vandalised hand rail, etc.
Residential areas seen by the adjudicator include:
Hillcrest – very well presented residential cul-de-sac. Grassed areas well maintained. Well done to all.
Residences on Chapel Street are well presented. Cottages on Barrack Street are eye catching.
Assumpta Terrace/St Bridget’s Park – these are hidden gems of Ballymore Eustace. Good landscaping.
Grassed areas well maintained. Some of the houses have attractive floral displays despite all of the rain this summer. Well done to all concerned.
Liffey Heights Court: grassed area well maintained. Some planters. Neat, tidy, no litter.

Roads, Streets and Back Areas:
Some of the road surfaces in Ballymore Eustace are poor including those near the Millennium Garden, a key feature in the village.
Footpath improvements noted.
Approach road from Poulaphouca: “Welcome to” stone and black and white village name sign on a nicely landscaped area at the junction, they combine to create a very good first impression of the village. It is a pity about the disused commercial premises nearby which is an eyesore.
Bishophill Road approach: residences on this road are very well presented. The adjudicator noticed an old red waterpump on the road side. Very good first impression. Road surface poor.
Approach on Coughlanstown Road: No Ballymore Eustace village sign. Well kept verges.
Naas Road approach: “Welcome to” sign on grass verge. Young trees. Not a great first impression.
L6053: no speed limit sign to define TidyTowns boundary. KTK Ltd entrance enhances the overall first impression.
Kilcullen Road approach: No village name sign.
Baltinglass Road approach: No village name sign. Used speed limit sign to mark TidyTowns boundary.
Average first impression.

General Impression:
The issues raised in your entry form have been noted and many have been commented on elsewhere in this report.
Ballymore Eustace TidyTowns Group has made further progress in the TidyTowns Competition. We look forward to receiving your new three year plan and your entry into the 2013 TidyTowns Competition.
Thank you Ballymore Eustace TidyTowns Group.

Tidy Towns Competition 2008
Adjudication Report

Centre: Ballymore Eustace             Ref:  357
County: Kildare                           Mark:  262
Category:   B                            Date(s):     07/07/2008                                                    

  Max.Mark Mark 2008
Overall Development Approach 50 33
The Built Environment 50 35
Landscaping 50 38
Wildlife and Natural Amenities 50 34
Litter Control 50 32
Waste Minimisation 20 5
Tidiness 30 16
Residential Areas 40 30
Roads, Streets and Back Areas 50 31
General Impression 10 8
Total Mark 400 262

Overall Development Approach:
NOTE : You were in Category C last year. You have applied for Category B this year. This is correct, as your population is within the B Category threshold as per Census 2006.

Go raibh maith agaibh go leir! Thank you to Ballymore Eustace TidyTowns and to the community you represent for having given selflessly of your time in working towards entering Ballymore Eustace in this 50th anniversary year of the TidyTowns Competition!
Ballymore Eustace is a small village with a good number of people involved on your committee. Your submission has been put together in a very professional format. It is most interesting, and informative, clear and extensive. You have drawn on the resources of many bodies, agencies and local businesses, including your local authority. You list these for us in your submission. Obviously they hold your group in high regard. You have an extensive media coverage organised. Thank you for letting us have copies of relevant media coverage. We hope that you communicate with all churches attended by any of your residents. Well done on your website. Thank you for submitting your five year plan. It is a pity that you did not detail the consultation process involved in drawing up your Plan. We assume that you held public meetings in this regard, but this is not clear from your submission, nor is it clear from the plan itself. We assume that you have launched your plan. We hope that it was well received. You appear to have listed specific projects for 2008 and 2009 only, with the rest included as "ongoing", presumably 2008-2013. Your school is a great resource for you. Thank you for enclosing the happy photograph of all your great helpers at Scoil Mhuire! We note your concern with the paperwork. We think that you have done "overtime” in this area! As you are starting out with a new plan, and as you are therefore engaging in a lot of paperwork now, the load should lessen. We hasten to say that it is appreciated and has helped us as adjudicators get to know the village well. The fact that it has all been submitted in A4 format has made it easier to use, and the fact that it is so well presented is also to your credit. So you can tell your members that it has been worth the effort! Your festivals are diverse, and you appear to have the edge on other places in Kildare when it comes to attracting in visitors with the festivals you can access. Thank you for submitting a clear map in your plan. However individual projects might be highlighted on a larger scaled map.

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Angler of the Year 2015

Anvil Bar Shield 27/09/2015 Winner Fergus Nolan 1lb 4.9ozs (593g)

Runner-up Mick Mooney 1lb 4.2oz (572g)

Jim Bolger Trophy 23/08/2015 Winner Des Tyrrell 1lb 1.8ozs (505g)

Runner-up Gay Doody 9.3ozs (265g)

Eddie Gordon Shield 24/07/2015 Winner Mel McKenna 10.8ozs (305g) 

Runner-up Gay Doody 9 ozs (255g)

No junior weighed-in

The ‘Local’ Trophy 03/07/2015 Winner Gay Doody 13.9ozs (394g)

Runner-up Mick Mooney 12.2 ozs (345g)

Junior Winner Lee McMullen 6.6 ozs (186g)

Sonny Cowley Shield 19/06/2015 Winner Mick McCafferty 1lb 2ozs (526g)

Runner up Mick Mooney  12.3 ozs (349g)

Junior Winner Lee McMullen 6.5 ozs (185g)

Mick Murphy Shield 05/06/15 Winner Tony Sweeney 13.9 ozs (393g)

Runner-up Robbie Winder 12.3 0zs (350g)

No junior weighed-in

Committee Cup 22/05/15 Winner Mick Francis 15.5 ozs (440g)

Runner-up Des Tyrrell 14.1ozs (399g)

Junior Winner Lee McMullen 9.1 ozs (257g)

Tony McKnight Trophy 10/05/15 Winner Des Tyrrell 2lb 1.1ozs (938g)

Runner-up: Fergus Nolan 1lb 12.4 ozs; (804g)

Punchestown Festival 26/04/15 Winner:  Gay Doody9.1 ozs; (258g)

Runner up: Eamonn Winder 8.8 ozs; (249g)

No Junior weighed in

J & K Murray Cup 12/04/15 Winner: Fergus Nolan 2lb; (915g)

Runner up: Mick McCafferty 13.2 ozs; (374g)

Junior Winner Lee McMullen 8.1 ozs (236g)

Jimmy Evans Cup 22/03/2015 Winner: Joe Winder   13.5 ozs; (382g)

Runner up: Willie Ryan 6.7ozs; (191g)

 

Angler of the Year 2014

 

Anvil Bar Shield 28/09/2014 Winner Mick Francis 1lb 5ozs (613g)

Runner-up Fergus Nolan 1lb 1 oz (507g)

Jim Bolger Trophy 24/08/2014 Winner Mick Francis 2lb 2.4ozs (963g)

Runner-up Mick McCafferty 1lb 11ozs (756g)

Eddie Gordon Trophy 25/07/2014 Winner Gay Doody 1lb 2 ozs (537g) 

Runner-up Mel McKenna 8.9ozs (257g)

No junior weighed-in

The ‘Local’ Trophy 04/07/2014 Winner Gay Doody 12.1ozs (343g)

Runner-up Mel McKenna 12.0 ozs (341g)

Junior Winner Ben Noone 15.4 ozs (437g)

Sonny Cowley Shield 20/06/2014 Winner Mick Mooney 2lb 6 ozs (1082g)

Runner up Joe Winder 1lb 2 ozs (529g)

Junior Winner Lee McMullen 13.8 ozs (390g)

Mick Murphy Shield 06/06/14 Winner Mel McKenna 13 ozs (370g)

Runner-up Mick Francis 9.5 0zs (268g)

Committee Cup 23/05/14 Winner Tom Nugent 2lb 5 ozs (1052g)

Runner-up Mick Francis 14.8ozs (420g)

Junior Winner Lee McMullen 10 ozs (286g)

Runner-up Aaron Roony 8.2 ozs (233g)

Tony McKnight Trophy 11/05/14 Winner Mick Mooney 9.7 ozs; (276g)

Runner-up: Gay Doody 8.5 ozs; (242g)

Punchestown Festival 20/04/14 Winner:  Thomas Hanzel 12.1 ozs; (343g)

Runner up: Gay Doody 11.8 ozs; (335g)

Junior Winner Aaron Rooney 7.4 ozs (209)

Runner-up Lee McMullen 5.2 ozs (146g)

J & K Murray Cup 06/04/14 Winner:  Eamonn Winder 1lb 2.4 ozs; (523g)

Runner up: Gay Doody 11.9 ozs; (337g)

Junior Winner Aaron Rooney 5.5 ozs (157g)

Runner-up Lee McMullen 4.8 ozs (135g)

Jimmy Evans Cup 23/03/2014 Winner:   Stan Huilx  ozs; (469g)

Runner up: Joe Winder ozs; (410g)

Junior Winner Lee McMullen 233g

Runner-up Aaron Rooney 207g

 

Angler of the Year 2013: Gay Doody

Heaviest Trout of the Year 2013: Fergus Nolan
Pike Competition 01/12/13 Winner: 

Runner-up:

Anvil Bar Perpetual Shield 29/09/13 Winner Fergus Nolan 2lb 5.3 ozs(1058kg)

Runner-up Mick Mooney 1lb 13.2 ozs (827g)

 

Jim Bolger Trophy 2/08/2013 Winner Mick Mooney 2lb 3.8ozs (1014kg)

Runner-up Mel McKenna 1lb 6.7ozs (645g)

Junior Winner Lee McMullen 6.5ozs (184g)

Eddie Gordon Trophy 26/07/2013 Winner Mick McCaffrey 15.4ozs (438g)

Runner-up James Noone 9.9ozs (281g)

The ‘Local’ Trophy 05/07/2013 Winner Gay Doody 1lb 2.6ozs (526g)

Runner-up Brian McDonagh 7.7ozs (219g)

Junior Winner Aaron Rooney 10.0 ozs (284g)

Junior R-up Lee McMullen 8.7ozs (248g)

Sonny Cowley Shield 21/06/2013 Winner Gay Doody 1lb 5.9 ozs (621g)

Runner up Mel McKenna 14.4 ozs (407)

Junior Winner Aaron Rooney 6.4 ozs (182g)

Mick Murphy Shield 8706/13 Winner Mel McKenna 8.4 ozs (237g)

Runner-up Mick Francis 8.1ozs (230g)

Committee Cup 24/5/13 Winner Gay Doody 1lb 3.2 ozs (543g)

Runner-up Des Tyrrell 12.8ozs (363g)

Tony McKnight Trophy 12/05/13Winner Mick Francis 1lb 12.5ozs; (808g)

Runner-up: Martin Keogh 1lb 1.5 ozs; (495g)

Punchestown Festival 21/04/13 Winner: Tomasc Hanzel 1lb 1.4 ozs; (492g)

Runner up: Gay Doody 14.6 ozs; (414g)

J & K Murray Cup 7/04/13 Winner: Gay Doody 1lb 1.5 ozs; (497g)

Runner up: Tomasc Hanzel 9.1 ozs; (259g)

Jimmy Evans Cup 24/03/2013 Winner: Martin Keogh 14.9 ozs; (422g)

Runner up: Gay Doody 10.4ozs; (295g)

 

 

Angler of the Year 2012: Gay Doody

Heaviest Trout of the Year 2012: Tom Nugent

BILD0544a.JPG

Details:
Wt: 1.862kg (4lb 1.7ozs)     Length: 54cm (21ins)      Date of capture: 8/6/12
Landed by Tom Nugent at Johnny Murphy’s on the River Liffey using a brown sedge wet fly. (Record weight recorded in a club angling competition)

Result of Scale analysis carried out by Dr. William Roche, Senior Research Officer, Inland Fisheries Ireland.

“Examined all scales submitted and all were replacements. This means that no intact scale available for analysis. Two had some detail (age/growth pattern) for past five years. It is not uncommon for older fish to have many replacement scales present. The inner portion of the scale was occluded due to the fact of it being a replacement and does not show any of the early life history of the fish. However I have attempted to age the fish based on previous information for the Liffey.
Using an old formula for ‘condition coefficient = 10^6 (W lbs)/427 (L)^3’ where W is the weight in pounds, L is the length in inches and assuming a condition coefficient of 1 (i.e. good condition), I estimated that the fish was approx. 54cm in length. Length is important information when looking at growth. There was significant scale erosion evident on the scales (indicative of a spawning mark) indicating that it had spawned two years previously. Some less pronounced spawning marks visible also.
From the above and the scales I am guesstimating that the fish was 7or 8 + years old based on previous scale readings from other trout from the Liffey and other information. This would put it into the fast or very fast category for growth of brown trout in Irish rivers based on a classification system devised by Kennedy and Fitzmaurice (1971).”

 

Pike Competition 02/12/12 Winner: Mick Francis 11 lbs (5.0kg) 

Runner-up Paul McGlynn 8 lbs (3.6kg)

Anvil Bar Perpetual Shield 30/09/12 Winner Mick Francis 2lb 7.6 ozs  (1.123kg)

Runner-up Fergus Byrne 2lb 6.1 ozs (1.081kg)

Guinness ‘All Methods’ 26/08/2012 Winner Fergus Nolan 2lb 7.3ozs (1.115kg)

Runner-up Fergus Byrne 2lb 7.1ozs (1.11kg)

Eddie Gordon Trophy 27/07/2012 Winner Fergus Nolan 12.5ozs (353g)

Runner-up Brian McDonagh 12.3ozs (348g)

The ‘Local’ Trophy 06/07/2012 Winner Gay Doody 1lb 3.7 ozs (559g)

Runner-up Mel McKenna 14.2ozs (404g)

Sonny Cowley Shield 22/06/2012 Winner Gay Doody 1lb 6.9 ozs (649g)

Runner up Fergus Byrne 1lb 4.5 ozs (580)

Mick Murphy Shield 8/06/12 Winner Tom Nugent 4lb 1.7 ozs (1.862kg)

(Record heaviest trout weighed-in at a competition)

Runner-up Des Tyrrell 1lb 3ozs (540g)

Committee Cup 25/5/12 Winner Viktor Miske 1lb 6.3 ozs (632g)

Runner-up Fintan Smith 1lb 4.3ozs (592g)

Tony McKnight Trophy 6/05/12 Winner Martin Reynolds 1lb 11.1ozs; (769g)

Runner-up: Mick Francis 1lb 6.1 ozs; (626g)

Punchestown Festival 22/04/12 Winner: Gay Doody 8.0 ozs; (228g)

Runner up: Mick Mooney 6.1 ozs; (173g)

J & K Murray Cup 8/04/12 Winner: Mick Mooney 11.1 ozs; (316g)

Runner up: Trevor Winder 9.4 ozs; (267g)

Jimmy Evans Cup 25/03/2012 Winner: Gay Doody 5.9 ozs; (166g)

Runner up: Mick Mooney 3.8ozs; (108g)

 

Angler of the Year 2011: Trevor Winder

Heaviest Trout of the Year 2011: Fergus Nolan

Pike Competition 04/12/11 Winner: Barry Brosnan (Draw)

Runner-up Pat Dunworth (Draw)

Anvil Bar Perpetual Shield 25/09/11 Winner Fergus Byrne 1lb 13.6 0zs (838g) 

Runner-up Willie Ryan 1lb 8.9 ozs (706g)

Guinness ‘All Methods’ 28/08/2011 Winner Fergus Nolan 1lb 15.3ozs (888g)

Runner-up Trevor Winder 1lb 12.9ozs (820g)

Eddie Gordon Trophy 22/07/2011 Winner Mick Mooney 13.8ozs (390g)

Runner-up Joe Winder 13.6ozs (385g)

The ‘Local’ Trophy 08/07/2011 Winner Trevor Winder 12.6 ozs (357g)

Runner-up Tony Daly 7.8 ozs (220g)

Sonny Cowley Shield 24/06/2011 Winner Mel Mc Kenna 1lb 6.9 ozs (650g)

Runner up Michael McCaffrey 1lb 0.2 ozs (460g)

Mick Murphy Shield 10/06/11 Winner Michael McCaffrey 1lb 0.8 ozs (475g)

Runner-up Mick Francis 12.3 ozs (348g)

Junior Section Winner Glen Rooney 11.1 ozs (314g)

Committee Cup 27/5/11 Winner Martin Nugent 13.8ozs; (392g)

Runner-up Fintan Smith 11.3; (319g)

Junior Section Winner by Glen Rooney 6.9 ozs (195g)

Tony McKnight Trophy 8/05/11 Winner Trevor Winder 1lb 11.5ozs;  (779g)

Runner-up: Tom Nugent 1lb 10ozs;(736g) 3rd. Fergus Byrne 1lb 7.1oz (654g)

Punchestown Festival 1/05/11 Winner: Gay Doody 10.4 ozs; (296g)

Runner up: Liam Cox; 9.4 ozs; (266g)

J & K Murray Cup 10/04/11 Winner: Pat Dunworth 8.4 ozs; (238g)

Runner up: Tomasz  5.7 ozs; (162g)

Jimmy Evans Cup 20/03/2011 Winner: Liam Cox 1lb 1.8 ozs; (505g)

Runner up: Fergus Nolan 13.2ozs; (375g)

Angler of the Year 2010: Trevor Winder

Heaviest Trout of the Year 2010: Martin Keogh

Pike Competition 05/12/10 Winner: Pat Dunworth (Draw)

Runner-up Martin Keogh (Draw)

Anvil Bar Perpetual Shield 26/09/10 Winner Troy Francis 1lb 6.5 ozs (637g)

Runner-up Tommy Winters 1lb 4.2 ozs (573g)

Guinness ‘All Methods’ 29/08/2010 Winner Martin Keogh 2lb 1.3ozs (943g)

Runner-up Martin Reynolds 1lb 13ozs (821g)

Eddie Gordon Trophy 06/08/2010 Winner Trevor Winder 1lb 3.2ozs (544g)

Runner-up Tony Daly 12.3ozs (348g)

The ‘Local’ Trophy 9/07/2010 Winner Fintan Smith 12.3 ozs; (348g)

Runner-up Joe Winder 10.7 ozs; (303g)

Sonny Cowley Shield 25/06/2010 Winner Trevor Winder 1lb5.6ozs; (613g)

Runner up Ollie Keogh 12.9 ozs; (352g)

Mick Murphy Shield 11/6/10 Winner Des Tyrrell 1lb 1.1 ozs (479g)

Runner-up Trevor Winder 13.3ozs (379g)

Committee Cup 21/5/10 Winner Ollie Keogh 13.8ozs; (390g)

Runner-up Joe Winder 13.7; (388g)

Tony McKnight Trophy 9/5/10 Winner Michael Mc Caffrey 1lb 3.6ozs;  (556g)

Runner-up Trevor Winder 12.2ozs;(347g)

Punchestown Festival 18/04/10 Winner: Gay Doody 13.8 ozs; (392g)

Runner up Martin Keogh; 9.5 ozs; (270g)

J & K Murray Cup 11/04/10 Winner: Martin Keogh 1lb 1.7 ozs; (503g)

Runner up Joe Winder 9.3 ozs; (265g)

Jimmy Evans Cup 21/03/10 Winner: Tom Nugent 10.8 ozs; (306g)

Runner up Fergus Byrne 10.4ozs; (295g)

Angler of the Year 2009: Trevor Winder

Heaviest Trout of the Year 2009: Michael Mooney

Junior Heaviest Trout of the Year 2009: Barry Winder

Pike Competition 06/12/09 Winner: Mick Francis 14lb

Runner-up Sean Goulding  11.5lb

Anvil Bar Perpetual Shield 27/09/09 Winner Martin Keogh 2lb 7.6 ozs (1124g)

Runner-up Mick Francis 1lb 10.3 ozs (745g)

Guinness Trophy(All Methods) 30/08/09 Winner Pat Dunworth 1lb 12.6 ozs 812g

Runner-up Martin Keogh 1lb 12.4 ozs (806g)

Eddie Gordon Trophy 07/08/2009 Winner Mick Mooney 3lb 2.2 ozs (1420g)

Runner-up Trevor Winder 2lb 2.8 ozs (987g)

The ‘Local’ Trophy 10/07/2009 Winner Trevor Winder 15.6ozs; (443g)

Runner-up Richie Stenson 12.8 ozs; (362g)

Sonny Cowley Shield 19/06/2009 Winner Pat Dunworth 15.6ozs; (442g)

Runner up Niall Brosnan 12.2 ozs; (347g)

Mick Murphy Shield 05/06/2009 Winner Fergus Byrne 12.3 ozs; (350g)

Runner up Brian Rigney  11.7 ozs (332g)

Junior Winner Simon Ellis 5.5 ozs (155g)

Committee Cup 22/5/09 Winner Trevor Winder 1lb 6ozs; (623g)

Runner-up Billy O’Brien 1lb 4.9ozs; (592g)

Junior Winner Barry Winder 9 ozs; (256g)

Tony McKnight Trophy 10/5/09 Winner Trevor Winder 1lb 7.9ozs;  (677g)

Runner-up Gay Doody 8.2ozs;(233g)
Punchestown Festival 26/04/09 Winner: Gay Doody 13ozs; (371g)

Runner up Billy O’Brien; 11.6 ozs; (328g)

J & K Murray Cup 05/04/09 Winner: Billy O’Brien 1lb 2.8 ozs; (532g)

Runner up Joe Winder 11.7 ozs; (331g)

Jimmy Evans Cup 15/03/09 Winner: Billy O’Brien 9.8 ozs; (279g)

Runner up Trevor Winder 9.7ozs; (275g)

Angler of the Year 2008: Martin Keogh

Heaviest Trout of the Year 2008: Michael Mooney

Junior Angler of the Year 2008: Troy Francis

Junior Heaviest Trout of the Year: Patrick Langan

Pike Competition 07/12/08 Winner: Fran Byrne19lb

Runner-up Martin Reynolds  10lb

Anvil Bar Shield 28/9/08 Winner: Michael Mooney  3lbs 11.2 ozs; (1680g)

Runner-up Michael Francis 1lb 6.8ozs; (646g) 

Guinness Trophy 31/8/08 Winner:  Michael McCaffrey 2lbs 3.9 ozs; (1018g)

Runner-up Tom Nugent 1lb 6.3ozs; (631g)

Eddie Gordon Trophy 8/8/08 Winner Joe Winder 13.4 ozs; (380g)

Runner-up Martin Keogh 13.1ozs; (371g)

Junior Winner Christy Walsh 7.2 ozs; (204g)

The ‘Local’ Trophy 11/7/08 Winner PeterMcGlynn 1lb 5.1ozs; (598g)

Runner-up Liam Stenson 1lb 3.2 ozs; (544g)

Junior Winner Troy Francis 5.8 ozs;(165g)

Sonny Cowley Shield 20/06/08 Winner Ollie Keogh 12.9 ozs; (366g)

Runner-up Sean Goulding 12.0 ozs; (339g)

Junior Winner Troy Francis 11ozs; (312g)

Mick Murphy Shield 6/6/08 Winner Des Tyrrell 1lb 8 ozs; (681g)

Runner-up Martin Keogh 1lb 1.5 ozs; (497g)

Junior Winner Troy Francis 8.2 ozs;(233g) Runner-up Eoin Lyons 7.7 ozs; (216g)

Committee Cup 23/5/08 Winner Gary Bolger 15.1 ozs; (427g)

Runner-up Martin Keogh 12.1ozs; (344g)

Junior Winner Simon Ellis 7.3ozs; (206g) Runner-up Eoin Lyons 5.5 ozs; (155g)

Tony McKnight Trophy 11/5/08 Winner Mick Francis 2 lb 1.3 ozs; (944g)

Runner-up Tommy Winters 1lb 11.6ozs; (782g)

Junior Winner Troy Francis 1lb 1.7 ozs (503g)

Punchestown Festival 20/4/08 Winner Sean Goulding 1lb 5.9 ozs; (620g)

Runner-up Trevor Winder 1lb 1oz (457g)

Junior Winner Patrick Langan 1lb 2.7 ozs; (531g)

J & K Murray Cup 6/4/08 Winner Liam Cox 7.7 ozs (217g)

Runner-up Peter McGlynn 5.9ozs; (167g)

Jimmy Evans Cup 16/3/08 Winner Martin Keogh 1lb 6.1ozs (627g)

Runner-up Sean Goulding 1lb 1.4ozs; (493)

 

KILDARE COUNTY COUNCIL

PUBLIC INFORMATION EVENING

BALLYMORE EUSTACE SEWERAGE SCHEME

As work on the contracts relevant to the Ballymore Eustace Sewerage Scheme is about to commence, Kildare County Council has arranged for a public information evening about the project to be held in the Ballymore Eustace Resource Centre on Tuesday the 22nd of January, 2013, from 6:00 pm to 8:30 pm.

Plans and particulars of the scheme will be on display for the duration of the evening. Representatives from the contractors and consulting engineers, along with associated members of staff will be available to explain the works and answer any questions relevant to the project. All are cordially invited to attend.

G. Halton
Senior Executive Officer
Water Services Section
Kildare County Council

The information night from 6pm to 9pm was a great success with many people expressing great satisfaction at the proposed plans.

Present at the meeting included:

Representing Kildare County Council: Joe Boland, Director of Services, Liam Crawford, Tim O’Connor, Paul Batty. For Consultants Nicholas O’Dwyer: Terry O’Flannagan, Martin O’Connell. For Contractors Ward & Burke: Pat Barrett. For Contractors Resource Engineering: Alan Dolan. A large representation of the general public including most of the committee members of the Trout and Salmon Anglers’ Association.

The Ballymore Eustace Trout and Salmon Anglers’ Association are pleased that as we argued at the Bord Pleanala Oral Hearing back in 1999 (when Abbeydrive were seeking planning permission to build a new sewage treatment plant at the site of the existing sewage treatment plant at the Strand) that any new plant should be constructed downstream of Ballymore Eustace village. While the Inspector dealing with the Oral Hearing agreed with our case Bord Pleanala granted permission for the proposed plant to be built on the existing site.

However, An Bord Pleanala refused permission to Abbeydrive to build the 416 houses which had been grated permission by Kildare County Council at the 40 Acres, Ballymore Eustace and so, Abbeydrive Developments did not go ahead and build a new sewage treatment plant now referred to as Waste Water Treatment Plant (WWTP) 

Despite all that has been achieved in the past number of years Ballymore Eustace has suffered one major drawback and that is the lack of a modern sewage treatment plant or waste water treatment plant as they are now called.  Perhaps in one way this was a blessing in disguise as it prevented the wholesale destruction of a Special Village by huge speculative developments such as the 507 houses at the ’40 acres’ or the 73 houses at Bishopshill or a similar number at Doran’s Park, Susheen.  Under the present circumstances, it might now be easier for Ballymore Eustace to develop in a controlled way.
On the down side, Ballymore Eustace has many derelict sites that need to be developed such as the old Donaghy’s Garage site, Oliver Plunkett Road site, Site opposite the Band Hall, Site between Barrack Street and Oliver Plunkett Road, etc.  All towns and villages need to develop and grow in a controlled way; otherwise, they just stagnate and die.  Ballymore Eustace is one of only a few places in Leinster to have suffered a decline in population in the April 2006 Census (population 725) but to many peoples surprise the population of the village increased by 147 to 872 people in the April 2011 Census but the population of the parish decreased from 1524 in 2006 to 1475 in 2011.

A short history of attempts to upgrade the sewage treatment plant in Ballymore Eustace might help highlight the difficulty in attempting to draw up a development plan for Ballymore Eustace.
Since the mid 1980’s Kildare County Council has promised a new sewage treatment plant for Ballymore Eustace.  At first, the village was to be linked to the Upper Liffey Valley Regional Sewage Treatment Plant at Osberstown, Naas, Co. Kildare.  Policy later changed and Kildare County Council decided that Ballymore Eustace would get its own Sewage Plant. 

Things dragged on until 1998 when Abbeydrive Development sought planning permission from Kildare County Council for 507 houses at the ‘40 acres’ Broadleas, Ballymore Eustace. Abbeydrive also sought permission to build a 2000 P.E. Sewage Treatment Plant at Kildare County Council’s existing site at the Strand, Ballymore Eustace.  However, An Bord Pleanala refused planning permission for the 416 house development which Kildare County Council had granted  but did grant planning permission for the proposed new sewage treatment plant. As expected without permission to construct the houses the Developer did not construct a new Sewage Treatment Plant. These Developments were the subject of a Bord Pleanala Oral Hearing. 

On the 6th October 2005, Kildare County Council announced in the local press that it intended to construct a new Waste Water Treatment Plant at Susheen, Ballymore Eustace and convert the existing plant at the Strand to a pumping station.  However, an objection by the Health Service Executive dated 29th March 2006, on the basis that the proposed site was too close to an existing residence, put an end to this plan. 

In December 2007, the Council advertised under Part 8 of the Planning & Development Regulations 2001 their intention to construct a new sewage treatment plant, this time at a site downstream of the village at the Kimmeens, Ballymore Eustace with the existing plant being converted to a pumping station.  It appeared to be all systems go, as there was no objection to the proposed plant.  It was expected that the plant would be operational in 2009.  Site investigation surveys, archaeological surveys, landscape surveys were all carried out during 2008.  However, the village was devastated by a letter dated the 26th February 2009 from The Director of Services, Kildare County Council stating that due to the present financial crises the project was being reviewed by the Department of the Environment and indeed the Minister for the Environment Mr. John Gormley withdrew proposed funding under the Serviced Land Initiative.  The Council made a positive submission to the Department of the Environment “citing, in particular, the extent to which planning applications are currently on hold as well as the desirability of addressing water quality issues.” Representation was also made to the Minister for the Environment by the Ballymore Eustace Trout and Salmon Anglers’ Association requesting that the new plant be approved in order to prevent continued pollution of the Liffey and to allow the village to develop rather than stagnate and die.  Mr. Jack Wall T.D., on behalf of the Angling Association, put forward no less than five different Parliamentary Questions to the Minister concerning the proposed Ballymore Eustace Sewage Treatment Plant. The whole village was delighted when on the 19th April 2010 the Minister for the Environment Mr. John Gormley published the Water Services Investment Programme 2010-2012.  A total of €3,545,000 was allocated to the Ballymore Eustace Wastewater Treatment Plant.  Our delight was somewhat curtailed when we learned from the Director of Services, Water and Environment Dept., Kildare County Council that the Council itself must come up with 60% of the cost of the Sewage Plant. The Director of Services informed us on the 8th April 2011 that the best scenario at that moment was that the WWTP would go to tender in May 2011, commence construction in the 1st quarter of 2012 and be operational in the 4th quarter of 2012. This we were told depended on Kildare County Council coming up with 60% of the cost of the plant.  When the Minister for the Environment Mr. John Gormley included Ballymore Eustace WWTP in the 2010-2012 Serviced Land Initiative this meant 40% funding by the DoEHLG and 60% funding by Developers/KCC.  In an email dated 21st April 2011 to the three South Kildare T.D’s, the Director of Services informed them that Kildare County Council had applied to have the project approved as a conventional project with 78% funding by the DoEHLG and 28% funding by KCC. Jack Wall T.D., on behalf of Ballymore Eustace Trout and Salmon Anglers agreed to ask a Parliamentary Question of the Minister to find out the Ministers position. 
On the 21st April 2011 the Director of Services Kildare County Council met with developers interested in building in Ballymore Eustace and found that there was little prospect of private sector funding for the construction of the new sewage treatment plant at Ballymore Eustace bearing in mind that substantial dezoning took place in the village in the new County Development Plan 2011 – 2017.
Accordingly, as part of the annual review of the Water Services Investment Programme, Kildare County Council applied to have the project reapproved as a conventional project i.e. 78% funding from the Department of the Environment, Heritage and Local Government and 22% Kildare County Council.
The Director of Services Kildare County Council informed us that the new Minister for the Environment Mr. Phil Hogan T.D. was reviewing all spending by his Department.
A letter from The Director of Services to the TSAA dated 19th July 2011 states that —" the final consents from the Department are now expected and it is, therefore, envisaged the new sewerage treatment plant will shortly be going to tender. I will keep you appraised regarding progress.—"
The Department did consent to the new funding arrangement.

A reply was received to the following question submitted by Councillor Mark Wall from Water Services Kildare County Council at the Athy Area meeting on Monday 19th September 2011.
"Councillor Wall
That the council confirm the up to date position in relation to the new sewerage plant for Ballymore Eustace following previous meetings on this issue.
Water and Environmental Services.
Report: Matters are progressing well; all design aspects are complete, issues relating to accommodation works, wayleaves and contract documentation are currently being finalised. It is proposed that the project will go to tender before the end of the current year. There will be two contracts involved ie, the waste water treatment plant and the network. A construction period of approximately one year is envisaged.
The members will be kept informed on progress.
(Issued by G. Halton, Senior Executive Officer, Water Services)"

The Trout and Salmon Anglers on 31st January 2012 emailed the Director of Services, Water & Environment, Kildare County Council seeking a reason for the delay in tendering and received the following reply on the same date “The delay is certainly regretted tom but it does seem that issues are now resolved.. We met the dept of env inspector on 19 January and discussed the matter…the only outstanding issue currently , as far as I am aware, is to forward and agree budget projections. All design aspects and contract documents are finalised, wayleaves should be in-hand, and I see no reason why we cant go to tender before the end of February.”

A further email reply from the Director of Services dated 6th March 2012 stated “treatment plant now going to tender…got declg approval last week…..”
Then, on the 28th March 2012 the tender notices appeared on eTender. Two contracts, the main WWTP at the Kimmeens and the Pumping Station plus pipework at the Strand.

The EPA on the 17th February 2011 granted a Waste Water Discharge Licence for the proposed Waste Water Treatment Plant and one of the conditions is that it be operational by December 2012.

A Landscaping Plan for the old Sewage Plant site (new Pumping Station) which will totally transform this section of the Riverside Walk was agreed between Kildare County Council and the Ballymore Eustace Trout and Salmon Anglers’ Association and we are desperately awaiting its implementation.

At present, planning permission has been granted by Kildare County Council, with a condition attached that construction cannot start until the new Waste Water Treatment Plant is constructed, for a 59 bed Nursing Home at Tinnycross, 11 houses at Donaghy’s old Garage site, 4 houses in Barrack Street, 3 houses at Golden Falls.  The derelict house on Oliver Plunkett Road beside Paddy Murphy’s Pub was refused planning permission for apartments and three shop units solely because the present sewage treatment plant is overloaded.

 
A new sewage treatment plant will have numerous advantages for the village:
it will remove the existing dilapidated sewage plant away from the centre of the village and Riverside Walk/Linear Park amenity area and replace it with a landscaped pumping station.
it will remove current obnoxious smells from this amenity area.
it will transform the visual aspect and amenity value of the Riverside Walk.
it will cease the current discharges of raw sewage to the Liffey at the Riverside Walk amenity area.
it will improve the quality of the water in the River Liffey.
it will allow development and clean-up of the current derelict sites and buildings in the village.
It will allow the village to develop in a controlled way.  
 

Waste Water Discharge Authorisation
A system for the licensing or certification of waste water discharges (WWD) from areas served by local authority sewer networks was brought into effect by Mr John Gormley, Minster for the Environment, Heritage and Local Government on 27th September 2007.   The licensing and certification authorisation process was introduced on a phased basis commencing on 14th December 2007 in accordance with the requirements of  the Waste Water Discharge (Authorisation) Regulations, 2007 (S.I. No. 684 of 2007).
Up to this Local Authorities did their own thing.
Applications for WWDA were made on a time scale where the largest WWTPs had to apply earliest.
Licenses must be reviewed within 6 years after being issued but can be reviewed any time after 3 years.

Kildare County Council applied to the Environmental Protection Agency for a Waste Water Discharge Licence for Ballymore Eustace on the 27th February 2009.

When Kildare applied to the Environmental Protection Agency for a Waste Water Discharge Licence (WWDL) in respect of the discharge from Ballymore Eustace Waste Water Treatment Plant into the River Liffey the Ballymore Eustace Trout and Salmon Anglers Association (TSAA) made the following submission to the EPA.

SUBMISSION TO THE ENVIRONMENTAL PROTECTION AGENCY
PO Box 3000,
Johnstown Castle,
Co. Wexford,

Re: Application by Kildare County Council for a Waste Water Discharge Licence for the Ballymore Eustace Waste Water Treatment Plant discharge into the River Liffey.
(Register No. D0238-01)

The Ballymore Eustace Trout and Salmon Anglers’ Association wishes to make the following submission on Kildare County Council’s application (in accordance with the Waste Water Discharge (Authorisation) Regulations 2007) to the Environmental Protection Agency for a Waste Water Discharge Licence (WWDL) in respect of the discharge from Ballymore Eustace Waste Water Treatment Plant into the River Liffey.

The Association feels that there is something wrong in Kildare County Council applying for a WWDL for a proposed new sewage treatment plant that has not yet been sanctioned by the Department of the Environment.  We believe that Kildare County Council should have to apply for a WWDL for the existing overloaded Sewage Treatment Plant at The Strand, Ballymore Eustace.  The EPA would have no option but to refuse such a licence and in so doing would highlight Kildare County Council’s negligence for many years in not providing proper sewage treatment facilities in Ballymore Eustace and for allowing raw sewage to pollute the River Liffey upstream of the abstraction point to a large drinking water supply plant at Leixlip.  What is the status of the existing discharge if Kildare County Council is not seeking a licence for same?  Is it now an illegal discharge in accordance with the Waste Water Discharge (Authorisation) Regulations 2007?

The Association has for over thirty years been asking Kildare County Council to upgrade the existing sewage treatment plant at the Strand, Ballymore Eustace but without any success.  The sewage plant regularly discharges raw sewage into the Liffey at Ballymore Eustace Bridge and a sewage fungus has built up downstream of the discharge point.  We are therefore hopeful that the Department of the Environment will sanction the construction of the proposed new Waste Water Treatment Plant at the Kimmeens, Ballymore Eustace and put an end to the present disgraceful discharge into the Liffey.

We are concerned however about the combined effects of the Wicklow County Council’s Blessington Waste Water Treatment Plant discharging into Golden Falls Lake just upstream of Ballymore Eustace village and Kildare County Council’s proposed WWTP discharging into the Liffey at Ballymore Eustace.  The flow of the River Liffey at Ballymore Eustace is controlled under the terms of the Liffey Reservoir Act 1936 which allows the ESB to release  “compensation water” up to 1.5 cubic metres per second when the level in Poulaphouca Reservoir is below “low water level” i.e 581ft O.D.  The ESB may, if it suits their purpose, also shut off the flow of the Liffey completely.  However, under normal circumstances (i.e. water level in Poulaphouca Reservoir above 581ft O.D.), the ESB releases 1.5 cubic metres of water per second to maintain the flow of the Liffey and when generating electricity at Golden Falls Hydro Electricity Generating Station the ESB releases 30 cubic metres of water per second referred to locally as ‘flood water’.  There are therefore, only two flows to the Liffey at Ballymore Eustace, 1.5 m3/sec and 30 m3/sec.  For the past three years 2006, 2007 and 2008 the ESB has released a flow of 1.5 m3/sec. for 91.54%, 86.53% and 79.32% of the time respectively, and this includes the two extremely wet years of 2007 and 2008.  Dublin City Council are presently constructing a massive upgrade and extension of their Water Treatment Plant at Ballymore Eustace that will allow them to abstract 318 million litres of water per day (70 m.g.d.) from Poulaphouca Reservoir, so it is likely that the percentage times for a release of 1.5 m3/sec to maintain the flow of the Liffey will increase in future years.  It is imperative therefore that the assimilative capacity of the Liffey at Ballymore Eustace is based on a flow of 1.5 cubic metres per second.

(Note: On Thursday 9th April 2009 the flow of the Liffey was completely shut off due we were informed by the ESB to a power failure at Poulaphouca Power Station which in turn tripped Golden Falls Power Station.  It appears that the valve which discharges the compensation flow to the river closed and could not be reopened by remote control from Turlough Hill.  The ESB had to send a staff member to Golden Falls to reopen the valve manually to get the Liffey flowing again.  While it is perfectly legitimate under the Liffey Reservoir Act 1936 for the ESB to shut off the flow of the Liffey, how can this be allowed to happen?  A ‘fail-safe’ system  must be installed as a matter of urgency.  To allow anybody to shut off the flow of the Liffey must be unconstitutional and be in breach of the Water Framework Directive and the Habitats Directive)

The Association is totally opposed to the Applicant, on page 24 of the Design Report, using the mean river flow to calculate the assimilative capacity of the Liffey in terms of phosphorus. The Molybdate Reactive Phosphorus (MRP) concentration reported under the Phosphorus Regulations Quality Standards for Rivers, is a median value, not a mean value and the two values can differ significantly.  Using the same formula as the Applicant to determine the waste assimilative capacity of the Liffey at Ballymore Eustace using 1.5 m3/sec as the river flow gives the following result.

WAC = (Cmax – Cback) X F95 X 86.4

WAC = Waste Assimilative Capacity (kg/d)
Cmax = Maximum Concentration (mg/l)
Cback =Background Concentration (mg/l)
F95 = 95 Percentile Flow (m3/s)
86.4 = Conversion Constant

WAC = (0.03 – 0.01) x 1.5 x 86.4 kg/d MRP
= 2.59 kg/d MRP

The Association believes that since a MRP concentration of 0.03 mgP/l would only achieve a Biological Quality (Q) Rating / Q Index of 4, (S.I. No.258 of 1998) a more ambitious target, i.e. Q Index 4 – 5, should be the aim.  This would lead to the following calculation:

WAC  = (0.02 – 0.01) x 1.5 x 86.4 kg/d MRP
= 1.3 kg/d MRP

Examining the Ortho-Phosphate (mgP/l) figures in Wicklow County Council’s Water Analysis of Golden Falls Lake for the first six months of 2007 it appears to the Association that a background MRP concentration of 0.01 mgP/l is too conservative and a more likely figure is 0.015. This would change the above examples of Waste Assimilative Capacity for Phosphorous to 1.94 kg/d and 0.65 kg/d respectively.  The Association, therefore believes that the Applicant’s Waste Assimilative Capacity figure of 10 kg/d Total Phosphorus for the River Liffey at Ballymore Eustace is erroneous and dangerously too high.  Also, analysis submitted by the Applicant for water samples taken from Ballymore Eustace Upstream of the present Sewage Plant on the 13/11/08 and 23/11/08 show Ortho Phosphate concentrations of 0.05 mgP/l and 0.04 mgP/l respectively, and would lead one to believe that the Waste Assimilative Capacity of the Liffey at Ballymore Eustace has already been used up by Blessington WWTP discharging into Golden Falls Lake.

The Association is also concerned that the concentration of Total Phosphorus in Golden Falls Lake for the first six months of 2007 averaged 0.11 mgP/litre, and is off the radar with regard to the Phosphorus Regulations, Water Standards for Lakes (S.I. No. 258/1998).  Also, analysis of samples taken from the River Liffey at Ballymore Eustace Upstream of the present sewage treatment plant discharge point on the 13th and 23rd November 2008 and submitted by the Applicant show Total Phosphorus concentrations of 0.09 mgP/l and 0.07 mgP/l respectively.

Since the beginning of March 2009 (at least) the Liffey at Ballymore Eustace is polluted with an algae growth, which the Association believes is being caused by nutrients from the Blessington WWTP discharge into Golden Falls Lake.  While we are hopeful that this scum like algae is not having a detrimental affect on the spawning gravels or aquatic fly life, it is seriously reducing the recreational value of the Liffey and is unacceptable.

The Association respectfully requests the EPA to consider the combined effects the Blessington WWTP and the proposed Ballymore Eustace WWTP will have on the water quality of the River Liffey before issuing a Waste Water Discharge Licence.  We also request the EPA to set strict upper limits with regard to Phosphorus discharges from the WWTP.  A comprehensive monitoring programme of the WWTP and the Liffey downstream of the discharge point must be put in place. Anglers retrieve lines by hand through the water and often eat sandwiches at the riverside so it is important that Faecal Coliforms and Total Coliforms counts are carried out, and in the interest of health and safety, all results must be made available to the public on a monthly basis via the internet or by some other easily accessible means.

______________________________
Gary Bolger,
Honorary Secretary,
Ballymore Eustace Trout and Salmon Anglers’ Association
Barrack Street,
Ballymore Eustace,
Co. Kildare.
22nd April 2009

The Eastern Regional Fisheries Board (ERFB) sent in a submission dated 3rd September 2009.

The EPA on the 30th September 2009 requested Further Information from Kildare County Council and the Council replied dated 28th January 2010. As part of threir reply Kildare County Council stated as follows  “(ii) Kildare County Council has submitted an updated Assessment of Needs for “Water Services Investment Programme 2010 – 2012″ to the DoEHLG (on 23/10/09). Included in this assessment is the new WWTP for Ballymore Eustace, which has been identified as a needs priority for some time. The estimated project cost is €2.5m. The scheme is currently being processed under the Serviced Land Initiative Programme and there is recognition of the possibility that this project may need to transfer to the main capital investment projects list having regard to current funding shortfalls.

The EPA granted a WWDL for the Ballymore Eustace Sewage Treatment on  February 2011.  The Licence specifies that the sewage treatment plant must be operational by 31st December 2012.

Comparison of Discharge Parameters, Proposed New Plant and Old Plant (mg/l)

Parameter Proposed new WWTP Old WWTP (Average 2007-2008)
BOD 25 181
COD 125 504
Total Phosphorus (as P) 2 8
Ortho Phosphorus (as P) 1 4
Ammonia (as N) 5 28
Suspended Solids 25 228

As can be seen there will be a big inprovement in the discharge quality.

Following the issuing of the WWDL the Ballymore Eustace Trout and Salmon Anglers sent the following letter to various relevant authorities.

(more…)

Ballymore Eustace Trout and Salmon Anglers AssociationWicklow County Council’s Application for a Waste Water Discharge Licence into Golden Falls Lake.Wicklow County Council applied to the Environmental Protection Agency for a Waste Water Discharge Licence to discharge effluent from Blessington Sewage Treatment Plant into Golden Falls Lake.The TSAA made the following submission etc

BALLYMORE EUSTACE TROUT AND SALMON ANGLERS’ ASSOCIATION

Barrack Street,
Ballymore Eustace,
Co. Kildare.
5th September 2008

Environmental Protection Agency,
PO Box 3000,
Johnstown Castle,
Co. Wexford,

Re: Application by Wicklow County Council for a Waste Water Discharge Licence for the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake.(Register No. D0063-01)

Dear Sir/Madam,On behalf of the above Association I wish to make the following submission on Wicklow County Council’s application (in accordance with the Waste Water Discharge (Authorisation) Regulations 2007) to the Environmental Protection Agency for a Waste Water Discharge Licence in respect of the discharge from Blessington Waste Water Treatment Plant into Golden Falls Lake.When Wicklow County Council built a new Sewage Treatment Plant in Blessington in the mid 1980’s they and Dublin Corporation decided to discharge the effluent into Golden Falls Lake in order not to pollute Poulaphouca Reservoir.  If there was a danger of polluting Poulaphouca Reservoir then what chance had Golden Falls Lake, which is barely one hundredth the size of Poulaphouca Reservoir and with far less dilution available.  The 50 acre Golden Falls Lake is in County Kildare.  In November 1984 (Ref 295/84) Kildare County Council gave Wicklow County Council permission to lay the four mile long discharge pipeline from Blessington Sewage Treatment Plant through townslands in County Kildare in order to reach and discharge into Golden Falls Lake.  This ‘neighbours from hell’ act by Wicklow County Council met with considerable opposition from the people of Ballymore Eustace.  Despite all the assurances we received from Wicklow County Council, Kildare County Council and various Government Ministers we didn’t have to wait long before the EPA Report ‘Water Quality in Ireland 1998 – 2000’ pointed out that Golden Falls Lake in the year 2000 was in the Hypertropic Category i.e. a Very High level of Pollution.  Wicklow County Council’s first response was to blame Simpleseas Fish Farm at Poulaphouca Power Station as being primarily responsible for the pollution but this was categorically denied by Simpleseas and backed up by Kildare County Council who monitored the discharge from the fish farm.  It was pointed out by Simpleseas management that when the water level in Golden Falls Lake was lowered by the ESB in the summer of 2002 to allow maintenance work on Golden Falls Dam, a high (15 – 20 feet) sludge bank was visible at the Blessington Sewage Treatment Plant Discharge Point in Golden Falls and that this indicated that the Sewage Plant was primarily responsible for the pollution.  The Association believes that a site investigation should be conducted to find out if the sludge bank still remains and if so, then Wicklow County Council should be made remove the sludge and clean up the location.  Blessington WWTP can discharge an average of over 212 kg of suspended solids per week into Golden Falls Lake and up to in excess of 870 kg per week and the Association believes that this level of solids dumped into the Lake is unsustainable in the long term.

The Association was surprised to learn from the Waste Water Discharge application form that the ESB granted a licence to Wicklow County Council to discharge from Blessington into Golden Falls Lake (subject to volumetric and quality standards being achieved in the treated effluent) as we were not aware the ESB were a licensing authority and we respectfully request the EPA to examine this licence in detail.  The WWDL Application also states “A part of the discharge license agreement with the ESB provided for water quality monitoring on a monthly basis by Wicklow County Council.  This monitoring has been undertaken for the last 21 years by Wicklow County Council and the analysis of the data indicates a good quality receiving water with no adverse impacts evident from the wastewater treatment works discharge.”  How can Wicklow County Council make such a claim in light of the EPA Report ‘Water Quality in Ireland 1998 – 2000’ with regard to Golden Falls Lake?  Also, the Association believes that little if any sampling of the water in Golden Falls was carried out in the past year.

In a reply, concerning the Blessington WWTP discharge to Golden Falls Lake dated 2nd May 1985, to Mr. Joe Bermingham T.D. Minister of State, Department of Finance, Mr. John Carrick, County Engineer, Kildare County Council states inter alia … “The possibility of requiring Wicklow County Council to take the effluent to a point downstream of Ballymore Eustace was considered initially, but after examination referred to above, it was found unnecessary. Wicklow County Council were advised, however, that should unforeseen developments take place in the area which might increase a pollutional load on the river beyond accepted levels, then alternative arrangements would have to be made regarding the disposal of the effluent e.g. taking the discharge downstream of Ballymore, or the provision of tertiary treatment.”  We now know that it did not take long before the pollutional load increased “beyond accepted levels” even though the population of Blessington was well below the design capacity of the waste water treatment plant.  See Chapter 11 page 88 and Appendix 2 page 146 of the ‘Ballymore Eustace Trout and Salmon Anglers’ Association History 1974 – 2007’ (enclosed as an Appendix to this submission) for a pretty detailed account of the Association’s and local opposition to Wicklow County Council’s plans to discharge effluent from Blessington Waste Water Treatment Plant into Golden Falls Lake.  The Association believes that “unforeseen developments” have taken place as Wicklow County Council in the Wicklow County Development Plan 2004 – 2010 have now designated Blessington as a “Primary Local Growth Centre” and this warrants a whole new look at discharging into Golden Falls Lake just upstream of the village of Ballymore Eustace.

The 2002 and 2006 Census figures show that the population of Blessington increased from 2509 to 4018 respectively, an increase of 60.1%.  As provided in the Wicklow County Development Plan, Blessington is designated a ‘Primary Local Growth Centre’ with an indicative population in 2010 of 6,500.  In March 2007 Wicklow County Council put a new 6000 P.E. Blessington Waste Water Treatment Plant into operation.  It appears to the Association from these figures that the new plant will be overloaded almost as soon as it is built.  The Association also notes that sewage sludge is being imported from other villages in West Wicklow.  The Association was informed by letter dated 21st March 2003 that Wicklow County Council proposed to upgrade the Blessington Waste Water Treatment Plant to include tertiary treatment and phosphorous removal.  However we note from Wicklow County Council’s application notice for a Waste Water Discharge Licence (Wicklow People 13th August 2008) that the new Blessington Waste Water Treatment Plant is only a secondary treatment plant.  Why does Wicklow County Council keep trying to mislead us?  The Association is appalled to learn, from the analysis results of the final effluent in the application form for a discharge licence, that the new Blessington WWTP is not operating to Works Compliance Standard of phosphorus removal for a massive 76.9% of the time.  If this is already happening with a new plant, what are the prospects for the future.  We also note from the application that the coagulant used for phosphorus reduction is Aluminium Sulphate.  Is this the reason for the high background levels of aluminium recorded in the Liffey samples upstream of Dublin City Councils discharge to the Liffey at Ballymore Eustace from their Water Purification Plant. (Following a visit to the Dublin City Council Waterworks on the 13th July 2006, the Office of Environmental Enforcement EPA requested amongst other things “a calculation of the assimilative capacity of the River Liffey with regards to the levels of aluminium in the discharge from the treatment plant should be carried out.” (PAE2005/194)

Because of the circumstances that exist at Golden Falls Lake the Association has always held the view that the discharge from Blessington Waste Water Treatment Plant should never have been allowed into this small man made Lake just upstream of the village of Ballymore Eustace.  Golden Falls Lake was set up under the Liffey Reservoir Act 1936, which allowed the Electricity Supply Board (ESB) harness the Liffey at Poulaphouca for electricity generation and Dublin Corporation to abstract 5 million gallons of water per day for a public water supply.  Dublin City Council are now constructing a massive upgrade and extension of the Water Purification Plant at Ballymore Eustace which will allow them treat 70 million gallons of water per day (318 Ml).  Golden Falls Lake was constructed as a buffer Lake to collect the huge water flows that emit from Poulaphouca Hydro Power Station (30 MW) when it is generating electricity (each of the two turbines can discharge between 11 and 38 cubic metres per second into Golden Falls Lake depending on turbine output i.e. 76 m3/sec when both turbines are operating at 15 MW).  This water is then released in a much-reduced flow from Golden Falls Lake via Golden Fall Hydro Power Station (4MW) to the River Liffey.

Under the Liffey Reservoir Act 1936, the ESB may at all times release up to 1.5 cubic metres of water per second from Golden Falls Lake to maintain the flow in the River Liffey (referred to as compensation water in the 1936 Act) and when Poulaphouca Reservoir is above the low water level (581 ft OD in the 1936 Act) the ESB may also generate electricity and thus release large volumes of water (30 million galls of water per second) to the River Liffey downstream of Golden Falls.

With the increased volumes of water abstraction from Poulaphouca Reservoir there is now less hydro generation of electricity taking place and so there is less generation ‘floods’ on the River Liffey than heretofore.  In 2006 and 2007 the flow of the Liffey at Ballymore Eustace downstream of Poulaphouca and Golden Falls was 1.5 cubic metres per second for 91.54 % and 86.53% of the time respectively and 30 cubic metres per second for the remaining times.  It can be seen that, through the goodness of their heart, (believe it or not, the Liffey Reservoir Act 1936 allows the ESB to shut off the flow of the Liffey if that suits their purpose, but thankfully this has never happened) the ESB always release a flow into the Liffey downstream of Golden Falls Lake.

However, the Association does not believe that this is the case with the flow into Golden Falls Lake from Poulaphouca Reservoir.  The turbines at Poulaphouca Hydro Generation Station are used to control the water levels in Golden Falls Lake.  When the turbines are ‘on-load’ there is a huge volume entering and filling up the Lake but when the turbines are not ‘on load’ there is no flow into Golden Falls and the level in the Lake drops until the turbines again fill it up.  The discharge from Blessington Waste Water Treatment Plant is a continuous flow into Golden Falls Lake and we believe that this leads to a ‘slug’ discharge into the Lake, with little dilution when the turbines are not in operation, i.e. for the vast majority of the time, and this ‘slug’ only get a large dilution when the turbines are switched ‘on-load’ to maintain the water level in the Lake and for electricity generation.  This on–off operation also allows the solids to settle out on the bed of the Lake.

The Water Quality Management Plan for the Liffey Catchment specifies that the mean annual concentration for total Phosphate is not to exceed 0.035 mg/l P in Poulaphouca Reservoir in order to protect the beneficial uses in the Reservoir.  Figures for Golden Falls Lake during 2007 reveal the total Phosphorus concentration is above the 0.035 mg/l P level.  Faecal Coliforms counts of over 2400 were also recorded in the Golden Falls Lake during 2007.  The effects of the increased levels of water abstraction from Poulaphouca Reservoir by Dublin City Council and Kildare County Council’s generosity in allowing Wicklow County Council discharge into Golden Falls Lake are now coming home to roost.  A slimy fungus like growth has now appeared on the concrete slipway of Golden Falls Dam.  The ESB feel it necessary to erect a health and safety notice (see photo below) at Golden Falls Power Station in Ballymore Eustace but no such warning is deemed necessary by Wicklow or Kildare County Councils for anglers, water skiers or other users of Golden Falls Lake or the River Liffey.  Is there a health and safety issue with the Blessington WWTP discharge into Golden Falls Lake that the public and Lake users are not being told about?  The Association is also concerned, as it appears that Wicklow County Council took few, if any, water samples from Golden Falls Lake since July 2007.

There are a number of other discharges into Golden Falls Lake.  The Association was particularly concerned when Wicklow County Council and An Bord Pleanala in 2004 granted planning permission to Comfort Hotel Tulfarris to discharge the effluent from a proposed new sewage treatment plant for an extended Tulfarris Golf and Country Club Hotel and Tulfarris Village into Poulaphouca Gorge downstream of Poulaphouca Dam.  The only dilution available at this location would be the water that leaks from the Dam but the effluent would however make its way into Golden Falls Lake.  (See Chapter 14 page 151 of the Ballymore Eustace Trout and Salmon Anglers’ Association History 1974 –2007).  As far as the Association is aware, the new sewage treatment plant has not been constructed yet as it appears that the ESB will not allow the effluent be discharged through and onto their property.  Granting planning permission for this one mile long discharge outfall to Golden Falls shows that Wicklow County Council has little if any regard for the water quality in Golden Falls Lake or the beneficial uses of the Lake, as Golden Falls Lake is in County Kildare as is the village of Ballymore Eustace.  It is similar to dumping in a neighbour’s back yard.

Under the heading Attachment B.11: Significant Correspondence, Wicklow County Council states “There has been no incidents of non-compliance associated with this WWTP and thus the EPA have not had to issue Wicklow County Council with a section 63 notice” —.  When the Association first learned of the pollution of Golden Falls Lake from the EPA Report, we wrote to Wicklow County Manager by letter dated 5th February 2003 about the pollution of Golden Falls Lake.  This letter was copied to the Minister for the Environment and Local Government, Minister for Fisheries, Kildare County Manager, Eastern Regional Fisheries Board, Mr. Charles McCreevy T.D. Minister for Finance, Mr. Dick Roche T.D. Minister of State, TD’s and Cllrs. Billy Timmins, Liz McManus, Mildred Fox, Sean Power and Cllrs. Liam Kavanagh, John Dardis and Billy Hillis.  The Senior Executive Officer, Environmental Services Section, Wicklow County Council replied by letter dated 21st March 2003 which was also copied to all the above blaming the fish farm at Poulaphouca for the pollution and stating “(and nothwithstanding that this Council believes that it is not primarily responsible for the deteriorating situation), the Council, as part of its planned upgrading of its treatment facilities proposes to provide tertiary treatment including phosphorous removal, with the purpose of further reducing the impact of its discharge on the Golden Falls.”  There was a raft of correspondence concerning the pollution of Golden Falls between the various parties in the early part of 2003 including Ministers, TD’s, Kildare County Council and Councillors to Wicklow County Council.  As mentioned earlier, the management of the fish farm denied they were responsible for the pollution of the Lake and pointed out the 15-20 feet high sludge bank on the bed of the Lake downstream of the Blessington WWTP discharge, and from there down, sludge of 1.5 – 2.0 feet in depth.  Wicklow County Council in their WWDL Application obviously do not consider any of this ‘significant correspondence’.

The Association respectfully requests the Environmental Protection Agency to impose stringent tertiary treatment limits, nutrient removal conditions and monitoring arrangements, on Blessington Waste Water Treatment Plant Discharge and to consider possible alternatives to discharging into Golden Falls Lake just upstream of Ballymore Eustace.  Such alternatives might include discharging to Osberstown via Naas or discharging to Ringsend via City West.  Compensation packages would of course have to be negotiated with the relevant Local Authority.

Yours sincerely,_____________________________
Gary Bolger
Honorary Secretary

BALLYMORE EUSTACE TROUT AND SALMON ANGLERS’ ASSOCIATION
Barrack Street,                                                                                                  BallymoreEustace,                                                                                                                      Co. Kildare.                                                                                                                   5th September 2008

Mr. Padraig McManus,
Chief Executive,
Electricity Supply Board,
Lower Fitzwilliam Street,
Dublin 2,

Re: Application by Wicklow County Council for a Waste Water Discharge Licence for the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake.
(EPA Register No. D0063-01)

Dear Mr. McManus,

Wicklow County Council’s have applied (in accordance with the Waste Water Discharge (Authorisation) Regulations 2007) to the Environmental Protection Agency for a Waste Water Discharge Licence (WWDL) in respect of the discharge from Blessington Waste Water Treatment Plant into Golden Falls Lake.

When Wicklow County Council built a new Sewage Treatment Plant in Blessington in the mid 1980’s they and Dublin Corporation decided to discharge the effluent into Golden Falls Lake in order not to pollute Poulaphouca Reservoir.  If there was a danger of polluting Poulaphouca Reservoir then what chance had Golden Falls Lake, which is barely one hundredth the size of Poulaphouca Reservoir and with far less dilution available.  Most of the 50 acre Golden Falls Lake is in County Kildare.  In November 1984 (Ref 295/84) Kildare County Council gave Wicklow County Council permission to lay the four mile long discharge pipeline from Blessington Sewage Treatment Plant through townslands in County Kildare in order to reach and discharge into Golden Falls Lake.  It also appears from the WWDL Application that the ESB granted a licence for the discharge into Golden Falls Lake.  This ‘neighbours from hell’ act by Wicklow County Council met with considerable opposition from the people of Ballymore Eustace.  Despite all the assurances we received from Wicklow County Council, Kildare County Council and various Government Ministers we didn’t have to wait long before the EPA Report ‘Water Quality in Ireland 1998 – 2000’ pointed out that Golden Falls Lake in the year 2000 was in the Hypertropic Category i.e. a Very High level of Pollution.  Wicklow County Council’s first response was to blame Simpleseas Fish Farm at Poulaphouca Power Station as being primarily responsible for the pollution but this was categorically denied by Simpleseas and backed up by Kildare County Council who monitored the discharge from the fish farm.  It was pointed out by Simpleseas management that when the water level in Golden Falls Lake was lowered in the summer of 2002 a high sludge bank was visible at the Blessington Sewage Treatment Plant Discharge Point in Golden Falls and that this indicated that the Sewage Plant was primarily responsible for the pollution.

In a reply, concerning the Blessington WWTP discharge to Golden Falls Lake dated 2nd May 1985, to Mr. Joe Bermingham T.D. Minister of State, Department of Finance, Mr. John Carrick, County Engineer, Kildare County Council states inter alia … “The possibility of requiring Wicklow County Council to take the effluent to a point downstream of Ballymore Eustace was considered initially, but after examination referred to above, it was found unnecessary. Wicklow County Council were advised, however, that should unforeseen developments take place in the area which might increase a pollutional load on the river beyond accepted levels, then alternative arrangements would have to be made regarding the disposal of the effluent e.g. taking the discharge downstream of Ballymore, or the provision of tertiary treatment.”  We now know that it did not take long before the pollutional load increased “beyond accepted levels” even though the population of Blessington was well below the design capacity of the waste water treatment plant.  The Association believes that “unforeseen developments” have taken place as Wicklow County Council in the Wicklow County Development Plan 2004 – 2010 have now designated Blessington as a “Primary Local Growth Centre” and this warrants a whole new look at discharging into Golden Falls Lake just upstream of the village of Ballymore Eustace.

The 2002 and 2006 Census figures show that the population of Blessington increased from 2509 to 4018 respectively, an increase of 60.1%.  As provided in the Wicklow County Development Plan, Blessington is designated a ‘Primary Local Growth Centre’ with an indicative population in 2010 of 6,500.  In March 2007 Wicklow County Council put a new 6000 P.E. Blessington Waste Water Treatment Plant into operation.  It appears to the Association from these figures that the new plant will be overloaded almost as soon as it is built.  The Association also notes that sewage sludge is being imported from other villages in West Wicklow.  The Association was informed by letter from Wicklow County Council dated 21st March 2003 that Blessington Waste Water Treatment Plant was to be upgraded to include tertiary treatment and phosphorous removal.  However we note from Wicklow County Council’s application notice for a Waste Water Discharge Licence (Wicklow People 13th August 2008) that the Blessington Waste Water Treatment Plant is only a secondary treatment plant.  Why does Wicklow County Council keep trying to mislead us?  The Association is appalled to learn from the analysis results of the final effluent in the application form for a discharge licence that the new Blessington WWTP is not operating to Works Compliance Standard of phosphorus removal for huge 76.9% of the time.  If this is already happening with a new plant what are the prospects for the future.

Because of the circumstances that exist at Golden Falls Lake the Association has always held the view that the discharge from Blessington Waste Water Treatment Plant should never have been allowed into this small man made Lake just upstream of the village of Ballymore Eustace.  Golden Falls Lake was set up under the Liffey Reservoir Act 1936, which allowed the Electricity Supply Board (ESB) harness the Liffey at Poulaphouca for electricity generation and Dublin Corporation to abstract 5 million gallons of water per day for a public water supply.  Dublin City Council are now constructing a massive upgrade and extension of the Water Purification Plant at Ballymore Eustace which will allow them treat 70 million gallons of water per day.  Golden Falls Lake was constructed as a buffer Lake to collect the huge water flows that emit from Poulaphouca Hydro Power Station (30 MW) when it is generating electricity (each of the two turbines can discharge between 11 and 38 cubic metres per second into Golden Falls Lake depending on turbine output i.e. 76 m3/sec when both turbines are operating at 15 MW).  This water is then released in a much-reduced flow from Golden Falls Lake via Golden Fall Hydro Power Station (4MW) to the River Liffey.

Under the Liffey Reservoir Act 1936, the ESB may at all times release up to 1.5 cubic metres of water per second from Golden Falls Lake to maintain the flow in the River Liffey (referred to as compensation water in the 1936 Act) and when Poulaphouca Reservoir is above the low water level (581 ft OD in the 1936 Act) the ESB may also generate electricity and thus release large volumes of water (30 million galls of water per second) to the River Liffey downstream of Golden Falls.

With the increased volumes of water abstraction from Poulaphouca Reservoir there is now less hydro generation of electricity taking place and so there is less generation ‘floods’ on the River Liffey than heretofore.  In 2006 and 2007 the flow of the Liffey at Ballymore Eustace downstream of Poulaphouca and Golden Falls was 1.5 cubic metres per second for 91.54 % and 86.53% of the time respectively and 30 cubic metres per second for the remaining times.  It can be seen that, through the goodness of their heart, (believe it or not, the Liffey Reservoir Act 1936 allows the ESB to shut off the flow of the Liffey if that suits their purpose, but thankfully this has never happened) the ESB always release a flow into the Liffey downstream of Golden Falls Lake.

However, the Association does not believe that this is the case with the flow into Golden Falls Lake from Poulaphouca Reservoir.  The turbines at Poulaphouca Hydro Generation Station are used to control the water levels in Golden Falls Lake.  When the turbines are ‘on-load’ there is a huge volume entering and filling up the Lake but when the turbines are not ‘on load’ there is no flow into Golden Falls and the level in the Lake drops until the turbines again fill it up.  The discharge from Blessington Waste Water Treatment Plant is a continuous flow into Golden Falls Lake and we believe that this leads to a ‘slug’ discharge into the Lake, with little dilution when the turbines are not in operation, i.e. for the vast majority of the time, and this ‘slug’ only get a large dilution when the turbines are switched ‘on-load’ to maintain the water level in the Lake and for electricity generation.

The Water Quality Management Plan for the Liffey Catchment specifies that the mean annual concentration for total Phosphate is not to exceed 0.035 mg/l P in Poulaphouca Reservoir in order to protect the beneficial uses in the Reservoir.  Figures for Golden Falls Lake during 2007 reveal the total Phosphorus concentration is above the 0.035 mg/l P level.  Faecal Coliforms counts of over 2400 were also recorded in the Golden Falls Lake during 2007.  The effects of the increased levels of water abstraction from Poulaphouca Reservoir by Dublin City Council and Kildare County Council’s generosity in allowing Wicklow County Council discharge into Golden Falls Lake are now coming home to roost.  A slimy fungus like growth has now appeared on the concrete slipway of Golden Falls Dam.  The ESB feel it necessary to erect a health and safety notice (see photo below) at Golden Falls Power Station in Ballymore Eustace but no such warning is deemed necessary by Wicklow or Kildare County Councils for anglers, water skiers or other users of Golden Falls Lake or the River Liffey.  Is there a health and safety issue with the Blessington WWTP discharge into Golden Falls Lake that the public and Lake users are not being told about?  The Association is also concerned, as it appears that Wicklow County Council took few, if any, water samples from Golden Falls Lake since July 2007.

There are a number of other discharges into Golden Falls Lake.  The Association was particularly concerned when Wicklow County Council and An Bord Pleanala in 2004 granted planning permission to Comfort Hotel Tulfarris to discharge the effluent from a proposed new sewage treatment plant for an extended Tulfarris Golf and Country Club Hotel and Tulfarris Village into Poulaphouca Gorge downstream of Poulaphouca Dam.  The only dilution available at this location would be the water that leaks from the Dam but the effluent would however make its way into Golden Falls Lake.  As far as the Association is aware, the new sewage treatment plant has not been constructed yet as it appears that the ESB will not allow the effluent be discharged through and onto their property.  Granting planning permission for this one mile long discharge outfall to Golden Falls shows that Wicklow County Council has little if any regard for the water quality in Golden Falls Lake or the beneficial uses of the Lake, as most of Golden Falls Lake is in County Kildare as is the village of Ballymore Eustace.  It is similar to dumping in a neighbour’s back yard.

The Association has made a submission to the EPA on Wicklow County Council’s WWDL Application and respectfully request ESB to support our request to the Environmental Protection Agency that they impose stringent tertiary treatment limits, nutrient removal conditions and monitoring arrangements, on Blessington Waste Water Treatment Plant Discharge and to consider possible alternatives to discharging into Golden Falls Lake just upstream of Ballymore Eustace.

Yours sincerely,

_____________________________
Gary Bolger
Honorary Secretary

Photo of Notice did not copy
Health and Safety Notice at Golden Falls Power Station

Letters similar to above letter to ESB sent to the following requesting them to support our submission to EPA.

Kildare County Manager, Aras Chill Dara, Devoy Park, Naas.
Padraig McManus, Chief Executive, ESB, Lower Fitzwilliam Street, Dublin
Pat Doherty, CEO, Eastern Regional Fisheries Board, Blackrock, Co. Dublin.
The Secretary, An Taisce-National Trust for Ireland, The Tailors Hall, Dublin 8.
Mr John Cregan, Director Regional Health Office, Health Service Executive Dublin Mid Leinster, Clonminch, Tullamore, Co. Offaly.
Dr P.J. Claffey, Programme Manager, Health and Safety Authority, Metropolitan Building, James Joyce Street, Dublin 1.
Ballymore Eustace Community Development Association, CDA
By Hand, Golden Falls Water Ski Club.
Email Councillor Billy Hillis, Dunstown, Brannockstown, Naas, Co. Kildare

Ballymore Eustace Trout and Salmon Anglers’ Association

Barrack Street,
Ballymore Eustace,
Co. Kildare.
13th April 2009
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate,
McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir,

On behalf of the above Association I wish to complain about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. While we are keeping our fingers crossed that this scum like algae is not having a detrimental affect on the spawning gravels or aquatic fly life, it is seriously reducing the recreational value of the Liffey and is totally unacceptable.

Analyses figures for the first seven months of 2007 reveal very high levels of total phosphorus (up to 0.55 mg P/l) in Golden Falls Lake and we believe that this is the cause of the algae bloom in the River Liffey immediately downstream of Golden Falls and continuing for a number of miles downstream.

While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.

The Association requests the Environmental Protection Agency to examine the situation with a view to having the phosphorus concentrations in Golden Falls Lake reduced to acceptable levels that will not pollute the Lake and the Liffey.

Yours sincerely,

___________________________
Gary Bolger
Honorary Secretary

The above letter was sent on to the EPAs Waste Water Discharge Licence office dealing with Blessington.

Another letter
Ballymore Eustace Trout and Salmon Anglers’ Association

Barrack Street,
Ballymore Eustace,
Co. Kildare.
19th April 2010
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate, McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir/Madam,

On behalf of the above Association I wish to complain in the strongest possible terms about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. This scum like algae on the surface is seriously reducing the recreational and aesthetic value of the Liffey and is totally unacceptable.  Since there is also a filamentous algae covering the gravels it is impossible to say that it is not harming the aquatic invertebrates and fauna in the Liffey.

The Association reported a similar algae growth to the Office of Environmental Enforcement by letter dated 13th April 2009 but no action to remedy the pollution has to our knowledge been taken by the EPA, Wicklow or Kildare County Councils.  This is totally unacceptable.

Analyses figures from Wicklow County Council for the first seven months of 2007 (the only figures available to the Association) reveal very high levels of total phosphorus (up to 0.55 mg P/l) in Golden Falls Lake and we believe that this is the cause of the algae bloom in the River Liffey immediately downstream of Golden Falls and continuing for a number of miles downstream.

While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.  The ESB control the water flow through the Lake.

The Association requests the Office of Environmental Enforcement, Environmental Protection Agency to take immediate action to rid the Liffey of this horrible pollution.  Indeed it is time the EPA took a much firmer stance on all the sources of pollution to the Liffey in Ballymore Eustace.

Yours sincerely,

___________________________
Gary Bolger
Honorary Secretary

Copy:  Mr. Eddie Sheehy, Manager, Wicklow County Council
Mr. Michael Malone, Manager, Kildare County Council
Mr. Padraig McManus C.E. Electricity Supply Board.
Mr. Pat Doherty, C.E.O. Eastern Regional Fisheries Board.

Again, this letter was passed on to the EPA’s WWDL application office

And another letter
Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
25th April 2012
Office of Environmental Enforcement,
Environmental Protection Agency,
Regional Inspectorate, McCumiskey House,
Richview,
Clonskeagh Road,
Dublin 14.

Dear Sir/Madam,

On behalf of the above Association I wish to complain in the strongest possible terms about the polluted state of the River Liffey at Ballymore Eustace by an algae scum caused we believe by nutrients from Wicklow County Council’s Blessington WWTP discharge into Golden Falls Lake. This scum like algae on the surface is seriously reducing the recreational and aesthetic value of the Liffey and is totally unacceptable. It is impossible now for anglers to fly fish the Liffey at Ballymore Eustace without getting their lines and flies covered in algae. Also, since there is a filamentous algae covering the gravels there is a danger that this is harming the aquatic invertebrates, flora and fauna of the Liffey and this needs to be investigated.

The Association reported a similar algae growth to the Office of Environmental Enforcement by letter dated 13th April 2009 and again by letter dated 19th April 2010. In the mistaken belief that something was being done to remedy the situation we did not report the matter in 2011. However, no action to remedy the pollution has to our knowledge been taken by the EPA, Wicklow or Kildare County Councils.  This is totally unacceptable.

Since the algae is present upstream and downstream of Kildare County Council’s overloaded sewage treatment plant discharge at Ballymore Eustace, the Association believes that the source of the pollution is nutrients from the Blessington Waste Water Treatment Plant. While Wicklow County Council’s Blessington WWTP discharges into Golden Falls Lake, the Lake itself is in County Kildare.  The ESB control the water flow through the Lake and Licensed the discharge.

Wicklow County Council should never have been allowed discharge effluent from Blessington WWTP into Golden Falls Lake where a minimum dilution was not guaranteed and this injustice must be rectified. The Association requests the Office of Environmental Enforcement, Environmental Protection Agency to take immediate action to rid the Liffey of this horrible pollution.  Indeed it is time the EPA took a much firmer stance on all the sources of pollution to the Liffey at Ballymore Eustace.

Yours sincerely,

___________________________
Thomas Deegan
Honorary Treasurer
Copy:  Mr. Eddie Sheehy, Manager, Wicklow County Council
Mr. Michael Malone, Manager, Kildare County Council
Mr. Pat O’Doherty Chief Executive, Electricity Supply Board.
Mr. William Walsh, Inland Fisheries Ireland.

The Association has also sought the support of many other bodies.

An Taisce made a submission dated 19/09/2008 and Ballymore Eustace CDA made a submission dated 22/9/2008. The Eastern Regional Fisheries Board (ERFB) made a submission dated 3/9/2009 and S. Deegan made a submission dated 12/11/2009.

The EPA on the 19th June 2009 requested Further Information from Wicklow County Council.

Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare.
16th April 2011
Mr. Senan Colleran,
Hydro Manager,
Generation Operations,
ESB Energy International,
Ardnacrusha Gen. Stn.,
Castlebank,
Limerick,
Co. Clare.

Dear Mr. Colleran,

Thank you for your letter dated 10th April 2011 in response to our letter of the 28th February addressed to ESB Chief Executive, Mr. Padraig McManus.

In our letter of the 28th February 2011 we stated “The Association is also pleased that the EPA Inspector dealing with the WWDL application has vindicated our concerns about water quality in the River Liffey at Ballymore Eustace which were made know for many years and on many occasions to all the relevant authorities dealing with the River Liffey. Despite all the assurances to the contrary, the truth has finally emerged and the EPA Inspector tells us in her Report under the heading “Assimilative Capacity” that “At the design emission limit value (25 mg/l), there is no assimilative capacity in the receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
Also that “There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.”
Again, “There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.”

This is a terrible indictment of all the authorities operating on the upper Liffey. Despite publishing the Water Quality Management Plan for the Liffey Catchment back in 1993 and the Three Rivers Project Report in 2002, the Liffey at Ballymore Eustace is still in breach of European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).”
Since the ESB granted a licence to Wicklow County Council to discharge the effluent of Blessington Waste Water Treatment Plant into Golden Falls Lake just upstream of Ballymore Eustace it too bears some responsibility for the fact that the water quality in the Liffey at Ballymore Eustace Bridge (upstream of Ballymore Eustace sewage treatment plant) is in breach of the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Does ESB monitor and review the conditions set down in the discharge licence and does it receive the analytical results of the discharge and water quality in Golden Falls Lake on an ongoing and regular basis?

ESB was also involved in the expansion of the Tulfarris Golf/Country Club/Village on Poulaphouca Reservoir and we are aware that the Tulfarris sewage plant discharge to Poulaphouca Reservoir also had problems in the past.

The Association, therefore, does not believe that ESB can now ignore the fact that the water quality in the Liffey at Ballymore Eustace Bridge is in breach of the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009) as if ESB played no role in bringing about this situation. This however, does not imply any criticism of ESB’s overall management or other activities on the Reservoirs.

Yours sincerely,

__________________________
Thomas Deegan,

Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Mr. Ray Earle,                                                       Co. Kildare.
Eastern River Basin Project Coordinator,       16th April 2011
Block 1, Floor 4
Civic Offices,
Wood Quay,
Dublin 8.
Dear Ray,

The above Association wishes to make the following observations on the letter dated 21st March 2011 from Mr. Adrian Conway in response to our letter to you and Mr. Tom Leahy dated 28th February 2011.

In our letter of the 28th February 2011 we said “The Association is also pleased that the EPA Inspector dealing with the WWDL application has vindicated our concerns about water quality in the River Liffey at Ballymore Eustace which were made know for many years and on many occasions to all the relevant authorities dealing with the River Liffey. Despite all the assurances to the contrary, the truth has finally emerged and the EPA Inspector tells us in her Report under the heading “Assimilative Capacity” that “At the design emission limit value (25 mg/l), there is no assimilative capacity in the receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
Also that “There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.”
Again, “There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.”

This is a terrible indictment of all the authorities operating on the upper Liffey. Despite publishing the Water Quality Management Plan for the Liffey Catchment back in 1993 and the Three Rivers Project Report in 2002, the Liffey at Ballymore Eustace is still in breach of European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).”

In Mr. Conway’s letter, which appears to be using your report to him on the points raised in our letter, he states that “The Upper Liffey Report by the ERBD Office and Consultants CDM published in December 2009 concluded that there was no significant impact on waters arising from the small urban/village centres of Kilbride, Lacken, Ballyknockan and Valleymount.” This makes one wonder why other villages go to the trouble and expense of collecting and treating their sewage prior to discharge to water.

Also, it is my recollection that the Upper Liffey Report mentioned above, extended to the Liffey Bridge at Ballymore Eustace and again it makes one wonder why the fact that the water quality in the Liffey at Ballymore Eustace Bridge is “in breach of European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009)” was not highlighted. What is the point of these Reports if they don’t tell us in plain language when Regulations are being broken and in my opinion this casts doubts in the public mind about the testing carried out by the Mobile Monitoring Unit of the ERBD.

I would be obliged if you would let the Association know why it fell to the EPA Inspector to highlight the fact that the water quality in the Liffey at Ballymore Eustace Bridge is in beach of the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009) for a number of parameters?

Yours sincerely,

________________________________
Thomas Deegan
Honorary Treasurer

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
Ms. Grainne Oglesby,                                                   29th December 2011
Programme Officer,
Environmental Licensing Programme,
EPA Headquarters, P.O. Box 3000
Johnstown Castle Estate,
Co. Wexford.

WWDA Ref. No. D0063 – 01

Dear Ms. Oglesby,

With reference to the above waste water discharge application, the Association wishes to express our abhorrence at the Draft Licence issued by the ESB to Wicklow County Council in 1985 in respect of, what was then, a discharge from the proposed Blessington WWTP.

How could any responsible local authority and semi-state company agree to discharge treated sewage effluent from a potential population of 6000 people into a small reservoir without a guaranteed minimum dilution of the effluent? (See paragraph numbered 4 on third page of draft licence).
The population Growth Estimate Target for Blessington (Moderate Growth Town) in the Wicklow County Development Plan 2010-2016 is 7,500 in the year 2022.

The EPA Inspector tells us in her Report dealing with the Ballymore Eustace WWDL and the River Liffey immediately downstream of Golden Falls Lake (D0238-01) under the heading “Assimilative Capacity” that “At the design emission limit value (25 mg/l), there is no assimilative capacity in the receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution”.

Also that “There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.”

Again, “There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009).
Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.”

The discharge from Blessington WWTP should never have been allowed into Golden Falls Lake where a minimum dilution of the effluent cannot be guaranteed.

Also, how could Wicklow County Council make a financial commitment to construct the necessary infrastructure for the proposed Blessington WWTP knowing the ESB could terminate the Licence at only a months notice? (See paragraph numbered 5 on third page of draft licence)

In the absence of any signed agreement between the ESB and Wicklow County Council, the Association would have to question if any such signed agreement exists.

The Association requests, from an environmental perspective and in the interest of natural justice, that the Environmental Protection Agency refuse a WWDL to Wicklow County Council to discharge effluent from Blessington WWTP into Golden Falls Lake where a minimum dilution of the effluent cannot be guaranteed and that an appropriate time table of withdrawal by Wicklow County Council be drawn up.

Yours sincerely,

________________________________
Thomas Deegan
Honorary Treasurer

 

BALLYMORE EUSTACE TROUT AND SALMON ANGLERS’ ASSOCIATION

Broadleas,
Ballymore Eustace,
Co. Kildare.
29th May 2012
Mr. Bryan Doyle,
Director of Services,
Water and Environmental Services,
Wicklow County Council,
County Buildings,
Wicklow.
Re: Blessington Waste Water Treatment Plant Discharge to Golden Falls Lake.

Dear Mr. Doyle,

Thank you for your letter dated 23rd May 2012 and enclosures.

It is most disappointing when professional people have to resort to personal attacks as their only line of defence. I have no interest in trying to denigrate Wicklow County Council. My only concern is for the water quality of the Liffey at Ballymore Eustace, Co. Kildare downstream of Golden Falls Lake/Reservoir. As stated in the Eastern River Basin District report titled “Programme of Measures Pilot Study – Upper Liffey” which you yourself quoted “historically, Blessington Waste Water Treatment Plant has displayed elevated concentrations of nutrients.” Also, the EPA has in the past placed Golden Falls Lake in the Hypertropic Category i.e. a very high level of pollution. So, please get off you high horse and maybe address you criticisms at the man in the mirror. Monitoring alone never solved any problems as results have to be assessed and, if necessary, acted upon. I ask that Wicklow County Council stop acting ostrich like with regard to the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake and work with the Association in trying to solve a perennial problem of algae growth destroying the aesthetic and recreational value of the Liffey at Ballymore Eustace.

When granting a WWDL to Kildare County Council for the proposed new WWTP at Ballymore Eustace, the EPA Inspector in her report dated 2nd February 2011 stated
“The results of the assimilative capacity calculations are summarised as follows:

(i) Biochemical Oxygen Demand
At the design emission limit value (25 mg/l), there is no assimilative capacity in the
receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of2009 before consideration of the WWTP discharge contribution.

However, the calculations in Table 3.0 indicate, for a notionally clean river, at an
emission limit value of 25 mg/l BOD at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for BOD, based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is only 0.13 mg/l BOD. Therefore, the effluent design standard of 25 mg/l BOD has been set as the emission limit value from 31 December 2012 in the RL.

(ii) Phosphorus
There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
For a notionally clean river, at an emission limit value of 1 mg/l at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for orthophosphate based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.005 mg/l orthophosphate. The RL sets an emission limit value of 2 mg/l for total phosphorus (the effluent design standard) and an emission limit value of 1 mg/l for orthophosphate from 3 1 December 2012.
Condition 5 of the RL requires the licensee to continually reduce total phosphorus
emissions in the discharge.

(iii) Ammonia
There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.
For a notionally clean river and an emission limit value of 5 mg/l at 2,000 p.e., there
would be adequate assimilative capacity in the receiving water for ammonia based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.026 mg/l of ammonia. Accordingly, the RL set an emission limit value of 5 mg/l for ammonia from 31 December 2012 to ensure compliance with S.I. No. 272 of 2009.
Condition 5.1 of the RL requires the licensee to continually reduce ammonia emissions

Table 3.0 above highlights that other measures need to be put in place to reduce high
background concentrations of BOD, orthophosphate and ammonia in the receiving waters upstream of the WWTP if the River Liffey is to achieve good stutus under the Water Framework Directive. It is not the role of the Wastewater Discharge Licence to address these other pollutant sources, it can only address the waste water discharges.”

I am aware that the above is based on background water quality data from January 2007 to February 2009 and that the Blessington WWTP was upgraded in 2007.

Because the problem shows up in County Kildare, maybe Wicklow County Council feels it doesn’t have to address “these other pollutant sources”, but the Association has no intention of letting matters rest until the Liffey at Ballymore Eustace is as near as is possible to pollution free.
Looking at the monitoring results for Golden Falls Lake one thing sticks out like a sore thumb. There could be up to a tenfold increase in the ammonia concentration in Golden Falls Lake and the downstream samples in spring each year which coincides with the algae growth in the River Liffey.

Perhaps you can use your chemical knowledge and technical approach to convince me that this cannot be attributed to Blessington WWTP discharge into Golden Falls Lake and that it is merely a coincidence that it coincides with the algae growth in the River Liffey at Ballymore Eustace each year. Even better, maybe something can be done to reduce the ammonia concentrations in the Golden Falls Lake.

My understanding is that for ammonia the EQS for Surface Waters is 0.02 mg/l. The limit for the non-ionised form of ammonia under the Freshwater Fish Directive is 0.025 mg/l while the limit for non-ionised ammonia under the Salmonid Waters Regulations is 0.02 mg/l.

I include below a graph of the ammonia results from Golden Falls to illustrate and highlight the situation.

Yours sincerely,

_______________________________
Thomas Deegan
Honorary Treasurer

AmmoniaGFallsfeb11mar12

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Administration,                                                    Ballymore Eustace,
Environmental Licensing Programme,                Co. Kildare.
Office of Climate, Licensing & Resource Use,    30th May 2012
Environmental Protection Agency,
Headquarters,
P.O. Box 3000,
Johnstown Castle Estate.
Co. Wexford.

Waste Waster Discharge Licence Application Register No: D0063-01

Dear Sir/Madam,

The above Association recently received a copy of the monitoring results of Golden Falls Lake from Wicklow County Council for the period February 2011 – March 2012. It is obvious from the results that there is an increase in the concentration of ammonia in the Golden Falls Lake and downstream samples in the Spring of the year which coincides with the perennial problem of algae growth in the Liffey.

I have included a graph (with notes) to illustrate the occurrence.

The above Association respectfully requests the EPA to take this into account when processing the above Waste Water Discharge Licence Application.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

Graph did not copy.
Graph for illustration purposes only as graph will only accept definite figures (not <0.03 mg/l)
All ammonia monitoring results recorded as <0.03 mg/l have been given a value of 0.02 mg/l

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
19th June 2012
Ms. Laura Burke,
Director General EPA
Environmental Protection Agency Headquarters,
P.O. Box 3000,
Johnstown Castle Estate,
Co. Wexford.

Waste Waster Discharge Licence Applications Reg. No: D0063-01 & Reg. No. D0238-01
Agglomerations named Blessington, Co. Wicklow and Ballymore Eustace, Co. Kildare.

Dear Director General,

The EPA has issued Waste Water Discharge Licenses for the agglomerations named Blessington, Co. Wicklow (Reg. No. D0063-01) and Ballymore Eustace, Co. Kildare (Reg. No. D0238-01). For the most part, the above Association is well satisfied with the conditions of the licenses and are delighted that the monitoring data from the Blessington discharge must be presented in graphical format in the Data Management System.

We are, however, totally and utterly confused by what appears to us to be two conflicting EPA Inspectors Reports on the water quality in the receiving water of the Liffey at Ballymore Eustace.
Blessington WWTP discharges into Golden Falls Lake which is in Ballymore Eustace, Co. Kildare just upstream of Ballymore Eustace village. We do not agree with the Inspector that the discharge is into a “short section of river between Poulaphouca Reservoir and Golden Falls Lake”. This is the first time it has been described as such and gives a misleading impression of a running river at the point of discharge. In fact, the water level in Golden Falls Lake/Reservoir must be lowered to the original river level to reach the point of discharge.
Also, the Inspector has misinterpreted Part 6 of the Schedule to the Liffey Reservoir Act 1936 when he states “Compensation water must be provided from the reservoir to allow some water to continue to flow in the river downstream. Sufficient water must be let through to maintain the fish and wildlife that use the river, and the natural vegetation in and around it. This ensures that a suitable constant flow shall be available in the receiving water to provide the dilution for final effluent discharged at SW001.” In a letter dated 24th March 1986 to Mr. Alan Dukes T.D.  Minister for Justice, Mr. Kevin O’Donnell, Dublin Chief Engineer, states “Dear Mr. Dukes,
With reference to the query in your letter of 6th instant to the City Manager, the rights and duties of the Electricity Supply Board and the Corporation are covered by various provisions in the Liffey Reservoir Act, 1936. The Act guarantees to the Corporation, the absolute right to a draw of 20 million gallons daily while the level is above a specific minimum level. The Board has an absolute right to use the water as it pleases while the level is above the specified minimum level, and this would include the right not to discharge any water if that suited the Board’s purposes.
Below the statutory minimum level, the Board may not use the water for generation purposes but may, at its own discretion discharge up to 1.5m3 of water per second, averaged over the week. There is, therefore, no statutory minimum flow that must issue from the reservoir.”—
Mr. O’Donnell goes on to say and I agree, that historically the ESB has released 1.5 m3 /sec to the Liffey when not generating, but they do so at their own discretion. Dublin City Council now abstract 70 million gallons of water per day from Poulaphouca Reservoir.
The Inspector dealing with the Blessington discharge in section 8, page 7 of his report states under the heading European Communities Environmental Objectives (Surface Water) Regulations 2009, S.I. No. 272 of 2009  “The water quality downstream of the WWTP shows that the River Liffey complies with the water quality standards for BOD, ammonia and orthophosphate stipulated in S.I. 272 of 2009. It is considered that the primary discharge is not adversely impacting the chemical water quality of the receiving water.” This despite the fact that my submission dated 30th May 2012 using Wicklow County Council monitoring results, shows, in graphical format, the ammonia concentration in Golden Falls Lake for the month of March 2012 at 0.17 mg/l N i.e. in breach of S.I. 272 of 2009. To allow the Blessington WWTP discharge to raise the ammonia level in the receiving water by 0.084 mg/l N seems excessive given that the Ballymore Eustace WWTP will also discharge a short distance downstream of Golden Falls Lake.
Also, while I agree that the River Liffey is not designated as salmonid waters, the Water Quality Management Plan for the Liffey Catchment under the heading Water Quality Criteria states “68. In order to provide a general measure of protection for all beneficial uses, the Plan specifies the water quality criteria applicable to salmonid fish as the basis for the establishment of water quality standards.”

When granting a WWDL to Kildare County Council for the proposed new WWTP at Ballymore Eustace, the EPA Inspector in her report dated 2nd February 2011 stated
“The results of the assimilative capacity calculations are summarised as follows:
(i) Biochemical Oxygen Demand
At the design emission limit value (25 mg/l), there is no assimilative capacity in the receiving water for BOD based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 highlights that the 95%ile upstream concentration of BOD (6 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
However, the calculations in Table 3.0 indicate, for a notionally clean river, at an emission limit value of 25 mg/l BOD at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for BOD, based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is only 0.13 mg/l BOD. Therefore, the effluent design standard of 25 mg/l BOD has been set as the emission limit value from 31 December 2012 in the RL.
(ii) Phosphorus
There is no assimilative capacity in the receiving water for orthophosphate based on the quality standards under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Tables 3.0 highlights that the 95%ile upstream concentration of orthophosphate (0.203 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the WWTP discharge contribution.
For a notionally clean river, at an emission limit value of 1 mg/l at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for orthophosphate based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.005 mg/l orthophosphate. The RL sets an emission limit value of 2 mg/l for total phosphorus (the effluent design standard) and an emission limit value of 1 mg/l for orthophosphate from 3 1 December 2012.
Condition 5 of the RL requires the licensee to continually reduce total phosphorus emissions in the discharge.
(iii) Ammonia
There is no assimilative capacity in the receiving water for ammonia based on the 95%ile quality standard under the European Communities Environmental Objectives (Surface Water) Regulations, 2009, (S.I. No. 272 of 2009). Table 3.0 shows that 95%ile concentration upstream of ammonia (0.99 mg/l) is already in breach of S.I. No. 272 of 2009 before consideration of the primary discharge contribution.
For a notionally clean river and an emission limit value of 5 mg/l at 2,000 p.e., there would be adequate assimilative capacity in the receiving water for ammonia based on the 95%ile standard under S.I. 272 of 2009. The contribution from the primary discharge is very small, 0.026 mg/l of ammonia. Accordingly, the RL set an emission limit value of 5 mg/l for ammonia from 31 December 2012 to ensure compliance with S.I. No. 272 of 2009.
Condition 5.1 of the RL requires the licensee to continually reduce ammonia emissions.
Table 3.0 above highlights that other measures need to be put in place to reduce high
background concentrations of BOD, orthophosphate and ammonia in the receiving waters upstream of the WWTP if the River Liffey is to achieve good status under the Water Framework Directive. It is not the role of the Wastewater Discharge Licence to address these other pollutant sources, it can only address the waste water discharges.”

Following the granting of the WWDL to Kildare County Council I mentioned in a letter dated 28th February 2011 to the EPA Office of Climate Change, Licensing and Resource Use that this was a terrible indictment of all the Authorities operating on the upper Liffey, but the Inspector dealing with the Blessington WWDA does not even warrant it a mention.

Using the data for ammonia in Table 3.1 of the two Inspectors Reports it appears to me that the EPA has now licensed two point discharges that will take the ammonia concentration in the upper Liffey at Ballymore Eustace to a level in breach of S.I. 272 of 2009. (i.e. Background concentration 0.037mg/l, plus contribution from Blessington WWTP 0.084 mg/l, plus contribution from Ballymore Eustace WWTP 0.026 mg/l bringing the concentration up to 0.0.147mg/l)
How is the Liffey at Ballymore Eustace to achieve ‘good status’ by 2021?

I also feel aggrieved that correspondence addressed to me from Wicklow County Council and copied to the EPA was not put up on the EPA website. As I was not informed by Wicklow County Council that they were copying the correspondence to the EPA, this would have allowed me to send a copy my response to the EPA. For what it’s worth, I have enclosed a copy of my response to Wicklow County Council dated 29th May 2012.

I respectfully ask that the EPA explain what to me are two conflicting Inspector’s Reports on the water quality of the River Liffey at Ballymore Eustace and reduce the ELV for ammonia in the Blessington WWTP discharge. There is also a need to correct the misleading information in the Inspector’s Report.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

Encl.

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
4th July 2012

Administration,
Environmental Licensing Programme,
Office of Climate, Licensing & Resource Use,
Environmental Protection Agency,
Headquarters,
P.O. Box 3000,
Johnstown Castle Estate.
Co. Wexford.

Waste Waster Discharge Licence Application Register No: D0063-01

Dear Sir/Madam,

I feel aggrieved that correspondence dated 23rd May 2012 addressed to me from Wicklow County Council along with emails which were copied to the EPA were not put up on the EPA website in a timely fashion. As I was not informed by Wicklow County Council that they were copying the correspondence to the EPA, this prevented me sending a copy of my response to the EPA in time for it to be taken into account before the Inspector submitted his report.

For what it’s now worth, I enclose a copy of my response to Wicklow County Council dated 29th May 2012 which I hope will also be put on the website.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
3rd September 2012
Mr. Tom O’Reilly,
Office of Director General
Environmental Protection Agency Headquarters,
P.O. Box 3000,
Johnstown Castle Estate,
Co. Wexford.

Waste Waster Discharge Licence Applications Reg. No: D0063-01 & Reg. No. D0238-01
Agglomerations named Blessington, Co. Wicklow and Ballymore Eustace, Co. Kildare.

Dear Mr. O’Reilly,

Thank you for your acknowledgement of my letter dated 27th August 2012 and the attached copy of acknowledgement dated 20th June of my letter dated 19th June 2012.

I don’t know what happened but I did not previously receive the acknowledgement dated 20th June 2012.

Thanking you.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
27th August 2012
Ms. Laura Burke,
Director General EPA
Environmental Protection Agency Headquarters,
P.O. Box 3000,
Johnstown Castle Estate,
Co. Wexford.

Waste Waster Discharge Licence Applications Reg. No: D0063-01 & Reg. No. D0238-01
Agglomerations named Blessington, Co. Wicklow and Ballymore Eustace, Co. Kildare.

Dear Director General,

With reference to my letter dated 19th June 2012 on behalf of the above Association, I am extremely disappointed that despite the EPA’s Customer Charter, no acknowledgement or reply to my letter has been received. Also, a letter dated 4th July 2012 to Administration, Environmental Licensing Programme, Office of Climate Change, Licensing and Resource Use, has not been acknowledged or a reply received.

(Extract from EPA Customer Charter
Service by correspondence:
If you make enquiries by letter, fax or e-mail, we will:
➤➤ respond to you in your preferred format (e.g. letter, fax, e-mail and telephone) no later than 5 working days from receipt of the enquiry or within 20 working days in the case of an enquiry which is particularly complex
➤➤ contact and inform you when you can expect a full reply if we cannot meet these time frames
➤➤ use clear language as deemed appropriate to the recipient and explain any “unfamiliar” technical terms on request
➤➤ ensure that all our correspondence contains a contact name, telephone number, fax number and e-mail address
➤➤ ensure that automated out of the office email replies are updated regularly by staff
➤➤ if your correspondence relates to a matter that comes within the remit of another public body, we will endeavour to direct the correspondence to that body and inform you accordingly)

In my letter of the 19th June 2012 to you I mentioned that in dealing with Waste Water Discharge Applications for the agglomerations named Blessington, Co. Wicklow (Reg. No. D0063-01) and Ballymore Eustace, Co. Kildare (Reg. No. D0238-01) the EPA issued what appeared to my Association to be two conflicting EPA Inspector’s Reports on the water quality in the receiving water of the Liffey at Ballymore Eustace. Blessington WWTP discharges into Golden Falls Lake which is in Ballymore Eustace, Co. Kildare just upstream of Ballymore Eustace village.

Since our letter to you, the Association has now received the following very disturbing explanation for the two conflicting Inspector’s Reports on the water quality in the Liffey at Ballymore Eustace.

“The data used by the EPA in the Assimilative Capacity Report referenced by the Anglers’ Association was from urban waste water returns (upstream and downstream of Ballymore Eustace Waste Water Treatment Discharge). It is the Council’s understanding that this data was generated from staff in the local Waste Water Treatment Plant using basic equipment. The Council would feel that this data should not have been used by the E.P.A. in their report considering that there were existing National Monitoring Stations upstream and downstream for which reliable data is available. The data from these stations and the results are far more reliable (see attachment) and compare well with the County Council data below the Golden Falls dam for the same period. There were a number of outlying results which caused averages to elevate but the results from 2007-2009 confirmed good physiochemical status at Ballymore Bridge.

2. The Council notes that the EPA were quoting 95% results (highest 5% of results) in their report and not average results i.e. extreme rather than normal situation. Even accounting for this the EPA report figures are multiples of ten times higher than our results for the same period (see comparison of data attached).

3. The County Council is stating that the complaint would appear to be unfounded based on the National River Monitoring Data and Wicklow County Council Golden Falls Monitoring Data for the period 2007-2009 and also based on current data from 2011. The data shows from Golden Falls monitoring and Kildare National River Monitoring that there is a assimilative capacity for the current set up at Blessington. The ammonia concentrations are close to the limits and peaks have been experienced in the early part of this year. With regard to the limit for (un-ionised) ammonia, I wish to point out the Council does not analyse unionised ammonia.  The Council is not required to do so under the Water Framework Directive. The Council is measuring and quoting the sum of both forms of ammonia (unionised and ionised) referred to as total ammoniacal nitrogen by the EPA. The limit for Good Status in the S.I. 272/2009 for total ammoniacal nitrogen are average = 0.065 mg/l N, 95% = 0.14 mg/l N. Statistical data supplied shows the station monitored by Wicklow County Council downstream of Golden Falls is compliant with this limit as far as 2011 (data attached).”

Following the granting of the WWDL to Kildare County Council (Reg. No. D0238-01) for Ballymore Eustace, I mentioned in a letter dated 28th February 2011 addressed to Administration, EPA Office of Climate Change, Licensing and Resource Use (copied to the other relevant Authorities) that the assimilative capacity data quoted in the Inspector’s Report was a terrible indictment of all the Authorities operating on the upper Liffey, but apart from an acknowledgement no reply was received from the EPA.
Can the EPA now confirm that the data used by the EPA for Assimilative Capacity in the Kildare County Council Waste Water Discharge Application for the agglomeration named Ballymore Eustace should not have been used and that this explains the two conflicting EPA Inspector’s Reports on water quality in the Liffey at Ballymore Eustace.

Yours sincerely,

_____________________________
Thomas Deegan
Honorary Treasurer

Environmental Protection Agency
An Ghnionifimreacht um Chaomhnu Comhshaoil
Headquarters, PO Box 3000
Johnstown Castle Estate
County Wexford, Ireland
Thomas Deegan
Honorary Treasurer
Ballmore Eustace Trout and Salmon Anglers’ Association
Broadleas
Ballymore Eustace
Co. Kildare
19 September 2012

Our Ref: Waste Water Discharge Licences D0063-01 Blessington and D0238-01Ballymore Eustace

Dear Mr. Deegan
I refer to your letters dated 19 June 2012 and 27 August 2012, received on 20 June2012 and 28 August 2012 respectively in relation to the Waste Water Discharge
(WWD) licences reference numbers D0238-01, agglomeration named Ballymore Eustace (licensed 17 February 2012) and D0063-01, agglomeration named
Blessington (licensed on 12 June 2012). The Agency notes that both letters wereacknowledged on 20 June 2012 and 31 August 2012 respectively. However, I do apologise for our delay in responding to your letter of the 19 June 2012. In order toprovide you with a detailed response to your letter it was necessary to liaise with anumber of people within the Agency. This unfortunately led to the delay during aparticularly busy period and the customary annual leave period.

The Agency welcomes the statement that Ballymore Eustace Trout and Salmon Anglers’ Association “for the most part is well satisfied with the conditions of the
licences”, the following will address the confusion caused for your association andwhat appears to you to be conflicting EPA Inspector Reports.
Prior to the issue of waste water discharge licences, all discharges from waste water treatment plants (WWTP), including Ballymore Eustace WWTP and Blessington
WWTP, had to comply with the Urban Waste Water (UWWT) Regulations, 2001 (S.I.No. 254 of 2001 and amendments), which transposed the Urban Waste Water Treatment Plant Directive (91/271/EEC). All agglomerations have been required to submit WWD licence applications to the EPA, in accordance with the Waste Water Discharge (Authorisation) Regulations 2007, as amended.The population equivalent (p.e.) of the Ballymore Eustace agglomeration (estimated to be 1,509 in 2008) is below the 2,000 p.e., threshold where emission limit valuesare required under the Urban Waste Water Treatment Plant Regulation. However,’appropriate treatment’ is required for agglomerations less than 2,000 p.e., asspecified in Article 7 of the UWWT Regulations 2001. The term ‘appropriate treatment’is defined in the UWWT Regulations in terms of the level of treatment necessary toprotect water quality. It is acknowledged in the Inspector’s Report that there iseffectively no treatment of the waste water from the Ballymore Eustace WWTP.
Therefore, the WWD licence requires that the proposed WWTP be completed by the 31 December 2012 and the emission limit values (BOD of 25 mg/1, ammonia of 5 mg/1and orthophosphate of 1 mg/1) shall apply form 31 December 2012.
The Blessington agglomeration p.e., is greater than 2,000, (estimated current loading of 4,570) and therefore the emission limits specified for such discharges under the UWWT Regulations apply (i.e., BOD 25mg/l, COD 125mg/l and 35mg/l suspended solids).
The WWD licences for the two agglomerations set stricter emission limit values when compared to the Urban Waste Water Regulations. The more strict limits are set on the basis of the ‘combined approach’(1) which is required under the Waste Water Discharge (Authorisation) Regulations 2007, as amended. Therefore improvements inthe primary discharges from both agglomerations are required.
The following ten points address the number of concerns raised in your letter:

1. Discharge Point from Blessington Agglomeration
The grid reference for the final effluent discharge point, as submitted by the applicant, puts the point of discharge in a short (~1.5 km) narrows that links
the Poulaphouca Dam with Golden Falls Lake. The assessment is based on theflow from the Poulaphouca Dam and Golden Falls Lake. In addition, the ‘Watermaps’ mapping system on the Water Framework Directive website(www.wfdireland.ie) sets the boundary of Golden Falls Lake (WFD code: IE_EA_09_53) as starting approximately 500 metres downstream of the primary discharge point. The same mapping system identifies the short section of river between the Poulaphouca Reservoir and Golden Falls Lake as being the lower River Liffey (WFD code IE_EA_09_1870_1).

2. Part 6 of the Schedule to the Liffey Reservoir Act 1936
Part 6 of the Schedule states ‘ The Board [ESB] shall at all times (includingtimes at which the level of the water in the Reservoir is below low water level as hereinafter defined) be at liberty to discharge water from the Reservoir in such manner as the Board may think fit….. as flow for compensation (hereinafter referred to as “compensation water”) as compensation water to the river downstream of the dam.
In the Inspector’s Report, the provisions of the Act are explained as a means of further proving the ability of the River Liffey to assimilate the discharge.
The Inspector’s Report states: ‘The flow of water in the river at SW001 is subject to variability depending on the factors outlined above however it is anticipated that the flow will not be reduced to a level to cause any significant concern as the DWF volume through the dam is similar to the 95%ile flow of 1.53m3/s. This is due to the fact that Part 6 of the Schedule to the Liffey

(1)The Waste Water Discharge Authorisation Regulations 2007 (S.I. No. 684 of 2007), as amended, specify that a ‘combined approach’ in relation to licensing of waste water works must be taken, whereby the emission limits for the discharge are established on the basis of the stricter of either or both, the limits and controls required under the Urban Waste Water Treatment Regulations (S.I. No. 254 of 2001 and amendments) and the limits determined under statute or Directive for the purpose of achieving the environmental objectives established for surface waters, groundwater or protected areas for the water body into which the discharge is made.
Historical EPA monitoring data calculates the 95%ile flow in the river at the hydrometric monitoring station no. 09032 (approximately 250 m upstream of
the primary discharge point) is 1.53m3/s

3. Water Quality downstream of the Blessington Waste Water Treatment Plant (WWTP) discharge and the specified ammonia emission limit value

Historical monitoring data submitted by Wicklow County Council in support of their waste water discharge licence application for the Blessington agglomeration (Reg. No. D0063-01) demonstrates that the ammonia concentrations in the receiving water (Golden Falls Lake) are in compliance with the European Communities Environmental Objectives (Surface Water) Regulations, 2009 (S.I. No. 272 of 2009) (herein referred to as the Surface Water Regulations).
In your letter you refer to a monitoring result for Golden Falls Lake for ammonia (0.17mg/l) in March 2012. One monitoring sample result is not representative of the quality of a waterbody and compliance with the Surface Water Regulations is not based on just one result, the environmental quality standards are based on arithmetic mean and 95 percentile of monitoring results. The submission on the Blessington licence application, dated 30th May 2012, was considered by the Agency prior to the issue of the WWD licence (page 10 and 11 of the inspector’s report).
The WWD licence for the Blessington agglomeration, issued on 12 June 2012, also sets an emission limit value for ammonia of 5mg/l on the primary discharge which is considered sufficient to contribute towards continued compliance in the receiving water with the standards set in the Surface Water Regulations.

4. The Water Quality Management Plan for the Liffey Catchment
The Environmental Quality Standards set in the Surface Water Regulations are the applicable standards for the River Liffey and for most parameters are more stringent than the European Communities (Quality of Salmonid Waters) Regulations 1998 (S.I. No. 293 of 1988) which only apply to salmonid waters.
It should be noted that the River Liffey is not a salmonid water. The Water Quality Management Plan for the Liffey Catchment was adopted in 1997 and therefore it predates the publication of the Surface Water Regulations. The emission limit values set in the Blessington licence have been determined with a view to ensuring compliance with the Surface Water Regulations and the ‘combined approach’ specified in the Waste Water Discharge (Authorisation) Regulations.

5. Ballymore Eustace Trout and Salmon Angler’s Association letter dated 28/02/11
A letter, dated 28/02/2011, was received following the granting of the WWD licence for Ballymore Eustace (Reg. No. D0238-01), which was acknowledged by the EPA in a letter dated 10 May 2011. This letter is in relation to the Ballymore Eustace WWD licence application and was therefore not considered as a submission in relation to the Blessington WWD licence application. Therefore, it was not referred to in the Blessington Inspector’s report. The Office of Licencing Research and Resource Use will assess and provide a detailed response to this letter in due course.
The background concentrations of BOD, orthophosphate and ammoniaupstream of Blessington’s primary discharge point are compliant with the Surface Water Regulations. The inspector’s report for Blessington states that “monitoring results submitted by the applicant have demonstrated that the quality of the receiving waters in Golden Falls Lake is within the prescribed quality standards set out in the Surface Water Regulations for BOD, MRP and total ammonia.” Golden Falls Lake has been categorised as being moderate status by the Eastern River Basin District (ERBD). According to the ERBD River Basin Management Plan, 2009-2015 the reasons for the lake only achieving moderate status is for excessive chlorophyll production caused by the presence of elevated levels of phosphorous in the water. According to the ERBD, the presence of elevated phosphorous levels is thought to come from a combination of agricultural sources and from planning and development.
According to the inspector’s report for Blessington the WWTP discharge is not considered to be a cause of significant deterioration in water quality in Golden
Falls Lake. The Blessington WWD licence sets emission limit values for BOD, orthophosphate and ammonia which contribute towards compliance with the
Surface Water Regulations.

6. Ammonia concentration in the River Liffey
According to the Blessington inspector’s report, Reg, No. D0063-01, the water quality downstream of the WWTP discharge shows that the River Liffey
complies with the water quality standards for BOD, orthophosphate and ammonia stipulated in the Surface Water Regulations. The inspector’s reportstates that “ft is considered that the primary discharge is not adversely impacting the water quality of the receiving water.” The Blessingtoninspector’s report demonstrates that at the point of discharge there issufficient assimilative capacity in the receiving water for the primary discharge. Therefore an emission limit value of 5 mg/1 for ammonia was set in the WWDlicence to contribute towards compliance with the Surface Water Regulations.
It is noted that the Ballymore Eustace (Reg. No. D0238-01) primary discharge point is located approximately 2.6 km downstream of Blessington’s (Reg. No.
D0063-01) primary discharge point. The upstream and downstream monitoring data submitted with the Ballymore Eustace WWDL application indicates that
the River Liffey at these points does not comply with the Surface Water Regulations. Ambient monitoring provided as part of Ballymore Eustace WWDL
application indicates that there is no significant difference between the water quality upstream and downstream for ammonia.
However, it is considered that as a result of the installation of the proposed WWTP (due to be completed by 31 December 2012) and compliance with the
emission limit value for ammonia of 5mg/l (which applies from 31 December 2012) set in the WWD licence the increase in concentration of ammonia is
likely to be very small (contribution of 0.026 mg/1 ammonia from the primary discharge). There is also significant dilution provided in the receiving water at
95 percentile flow rates (approximately 191 dilutions). The above shall contribute towards compliance with the Surface Water Regulations.
The ERBD River Management Plan 2009 – 2015 identifies that an upgrade of Ballymore Eustace WWTP is required if the target date (2021) for good status
is to be achieved. Measures specified in the ERBD – Programme of Measures (2009-2015) for the Liffey Water Management Unit identifies measures to
protect and restore water status by addressing the main pressures such as waste water/industrial discharges, agriculture, landfill and forestry.

7. Availability on the EPA website of the letter from Wicklow County Council to the Ballymore Eustace Trout & Salmon Angler’s Association.
The letter from Wicklow County Council to Ballymore Eustace Trout and Salmon Angler’s Association dated 23 May 2012, was received by the Agency
on 24 May 2012 and is available to view on the EPA website at the following link: http://www.epa.ie/licences/lic eDMS/090151b280442449.pdf. The letter was
scanned to the EPA website on 31 May 2012, as per the date stamp on the letter.

8. Misleading information in the Inspector’s reports
It should be noted that the inspector’s reports are not legal documents and are for information purposes only. The WWD licence is the legal document
which authorises the discharge of waste water from the waste water works subject to a number of conditions. It is acknowledged in both reports, that the biological quality of the River LIffey is Q3-4 at the EPA monitoring station 09L010400 (downstream of Blessington’s WWTP primary discharge point and upstream of the existing Ballymore Eustace WWTP primary discharge). Both reports state that the Water Framework Directive status of the River Liffey is moderate and is
required to achieve ‘good’ status by 2021. Ballymore Eustace primary discharge point is located approximately 2.6 km downstream of Blessington’s primary discharge point. The upstream and downstream monitoring data submitted with the application for the Blessington WWDL indicates that the River Liffey complies with theEnvironmental Objectives (Surface Water) Regulations 2009. However, the upstream monitoring data (approximately 110m upstream of the primary
discharge point) submitted with the Ballymore Eustace WWDL application indicates that the River Liffey at this point does not comply with the Environmental Objectives (Surface Water) Regulations 2009.
The licences for Blessington and Ballymore Eustace WWDL’s, set emission limit values, with the aim of contributing towards achieving good water quality
status by 2021. Other measures need to be put in place for the river to achieve ‘good’ water quality status, such as the measures specified in theEastern River Basin Management Plan (2009 – 2015). There are a number of sources, such as other waste water/industrial discharges, agriculture, landfill and forestry, which may be contributing to the reduced water quality in theRiver Liffey between upstream of Blessington’s primary discharge and downstream of Ballymore Eustace primary discharge. It is not possible for the waste water discharge licences to address these other pollutant sources.
Both the Blessington and Ballymore Eustace WWDL’s set emission limit value with the aim of contributing towards compliance with the Surface Water
Regulations in the River Liffey.
One of the Eastern River Basin District (2009-2015) objectives for the Liffey is to restore the Liffey to good status by 2021. The Eastern River Basin
Management Plan (2009-2015) (available to download on the Water Framework Directive website: www.wfdireland.ie) identifies measures to protect and restore water status by addressing the main pressures (that is sources of pollution or status impact) in the district.

9. Request to reduce the emission limit value set for ammonia in theBlessington WWDL
The Agency considers that the emission limit value set for ammonia (5mg/l) for the Blessington primary discharge is sufficient to ensure continued compliance
in the receiving water with the standard for ammonia in the Surface Water Regulations.

10.Ballymore Eustace Monitoring data
The application was assessed based on monitoring data provided by Kildare County Council and EPA monitoring data. The assessment of the application is
described in the inspector’s report. The Agency considers that compliance with the requirements of the waste waterdischarge licences and the implementation of the other measures identified in the Eastern River Basin Management Plan (2009-2015) should contribute towards improvement of the status of the River Liffey to ‘Good’ by 2021. If you have further concerns in relation to the discharges from the Blessington and Ballymore Eustace WWTP’s, please contact the EPA’s Office of Environmental Enforcement, who are responsible for the enforcement of the WWDL’s, on 053-9160600.
Yours sincerely,

Frank Clinton-
Programme Manager
Environmental Licensing Programme

Ballymore Eustace Trout and Salmon Anglers’ Association

Broadleas,
Ballymore Eustace,
Co. Kildare.
28th September 2012
Mr. Frank Clinton,
Programme Manager,
Environmental Licensing Programme,
EPA Headquarters,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.

Ref: Waste Water Discharge Licences D0063-01 Blessington and D0238-01 Ballymore Eustace

Dear Mr. Clinton,

Thank you for your letter dated 19th September 2012 in response to mine dated 19th June 2012 and 27th August 2012 addressed to the Director General EPA.

Again, I must say that I did not receive any acknowledgement to my letter dated 19th June 2012 until it was enclosed with the acknowledgement to my letter of the 27th August 2012.

Kildare County Council expect to start work on the new Ballymore Eustace pumping station and Waste Water Treatment Plant shortly, but it remains to be seen if it will be completed by the 31st December 2012 as required by the Waste Water Discharge Licence (D0238-01). However, we look forward to the new plant replacing the present dilapidated, obnoxious plant that is creating a sewage fungus on one side of the Liffey downstream of the discharge point at The Strand, Ballymore Eustace. The new plant will discharge further downstream at Susheen, Ballymore Eustace.

I wish to make the following comments in relation to your ten point reply to our concerns as expressed in the above mentioned letters.

1. Discharge Point from Blessington Agglomeration.
Wicklow County Council sought permission in 1985 from Kildare County Council to construct an ‘outfall pressure pipe’ the “intended termini thereof are Blessington in the North and Golden Falls Lake in the South.” in order that they could discharge the effluent from Blessington WWTP into Golden Falls Lake. In their application for a Waste Water Discharge Licence, Wicklow County Council states “Sewage generated in the Blessington Agglomeration is collected and conveyed to the Waste Water Treatment Plant at Blessington where it undergoes secondary treatment before being discharged to the Golden Fall Lake.”
Golden Falls Lake was lowered to the original River Liffey level by the ESB to facilitate the laying of the discharge outlet. To this day Golden Falls Lake must be lowered to the original river level to access the discharge point.
The Gorge that links Poulaphouca Dam to Golden Falls Lake/Reservoir (i.e. over the old, now redundant Poulaphouca Waterfall and under Nimmo’s Bridge) was part of the River Liffey prior to the Liffey Hydro Electric Scheme of the early 1940’s. Today, the only flow in this section is what leaks through the Poulaphouca Dam and some minor springs. The water feeding Golden Falls Lake now comes through the Penstocks at Poulaphouca Dam, through Poulaphouca Power Station and then into Golden Falls Lake. Obviously, local knowledge from Wicklow County Council and others that Blessington WWTP discharges into Golden Falls Lake wasn’t good enough for the Inspector dealing with the WWDL for Blessington. The fact that someone got it wrong and put the Blessington WWTP discharge point presumably in the pre Liffey Scheme section of the Liffey and put this information on a map on a  website does not mean that it is correct. Websites are only as good as the information they are fed. Recently, a map on a website placed Dublin Zoo in Temple Bar and an Airport in Stillorgan but that didn’t make it right. Perhaps the EPA can use its influence to have the discharge point from Blessington WWTP correctly placed in Golden Falls Lake.

2. Part 6 of the Schedule to the Liffey Reservoir Act 1936
While you quote a section of Part 6 of the Schedule to the Liffey Reservoir Act 1936, you go on then to quote from the Inspector’s Report which misinterprets the Act when it states “—This is due to the fact that Part 6 of the Schedule to the Liffey Reservoir Act 1936 requires the ESB to release ‘compensation water’ up to 1.5m3/s when the level in Poulaphouca Reservoir is below ‘low water level’. The Act does not require the Board to do any such thing. The Act states that the Board may as it sees fit release compensation water up to 1.5m3/s. As explained by Mr. Kevin O’Donnell Dublin Chief Engineer, Engineering Services, in a letter dated 24th March 1986 to Mr. Alan Dukes T.D.  Minister for Justice, “The Board has an absolute right to use the water as it pleases while the level is above the specified minimum level, and this would include the right not to discharge any water if that suited the Board’s purposes.
Below the statutory minimum level, the Board may not use the water for generation purposes but may, at its own discretion discharge up to 1.5m3 of water per second, averaged over the week. There is, therefore, no statutory minimum flow that must issue from the reservoir.”  Since the Liffey Reservoir Act 1936 has never been amended this is still the case even though the ‘powers that be’ don’t want to admit it and continuously quote 95%ile flows. The flow of the Liffey was closed down completely for about two and a half hours on the 9th April 2009 when a fault closed down the discharge valve to the Liffey at Golden Falls Dam/Power Station. This is quite legitimate under Part 6 of the Schedule to the Liffey Reservoir Act 1936. To their credit, following representation from the Anglers’ Association, the ESB agreed to install a fail safe system. (my bold and italics above)

3. Water Quality Downstream of the Blessington Waste Water Treatment Plant (WWTP) discharge and the specified ammonia limit value
We are very disappointed with how easily the EPA can dismiss what could be the significance of a monthly sample. As the ammonia graph which we submitted (letter 30th May 2012) shows an increase in the ammonia concentration from January 2012 to February 2012 and again to March 2012 the concentration recorded for March may indeed represent the ammonia concentration in Golden Falls for almost two months (until the next sample was taken in April) or one sixth of the year and should not be dismissed out of hand even if it is only one sample. We are also disappointed that the WWDL for Blessington now extends the sampling frequency out to quarterly samples which means that many ‘events’ will now be missed.
In our letter dated 19th June 2012 we were expressing our anger and frustration that each year the Liffey at Ballymore Eustace becomes almost unfishable because of algae growth in the River at the start of the angling season in March/April. (The algae fouls up the flies used by the anglers.) When we received the analytical results for Golden Falls from Wicklow County Council for 2011 and early 2012, it was obvious to us that the ammonia concentration in Golden Falls Lake and the Liffey rose at the same time as the algae growth appeared. We graphed the results to highlight our concern. We were hoping that the EPA might apply their expertise to establish if there was a correlation between the two. Unfortunately for us and the Liffey at Ballymore Eustace the EPA appears to have dismissed it out of hand because the water quality is in compliance with the Surface Water Regulations, 2009. Even Wicklow County Council admits that “The ammonia concentrations are close to the limits and peaks have been experienced in the early part of this year.”

4. The Water Quality Management Plan for the Liffey Catchment
From about 1985 until it was adopted in 1997 anglers were led to believe that the Water Quality Management Plan for the Liffey Catchment would solve all our problems. In it we were reliably informed that even though the Liffey was not a designated ‘salmonid’ river it would be treated as a ‘salmonid’ river with regard to water quality standards. Now we are informed that it was superceded in 2009 by the Surface Water Regulations so the Water Quality Management Plan for the Liffey Catchment is not now worth the paper its written on. What a waste of time and effort by all who contributed to the Plan. Will the same faith happen to the Eastern River Basin Management Plan?

5. Ballymore Eustace Trout and Salmon Anglers’ Association letter dated 28/02/11
We thank the EPA for the reply dated 25th September 2012 and received on 26th Sept.

6. Ammonia concentration in the River Liffey
See 3. above.

7. Availability on the EPA website of the letter from Wicklow County Council to the Ballymore Eustace Trout and Salmon Anglers’ Association
I genuinely did not see this letter on the EPA website prior to the issuing of the Blessington WWDL even though I was keeping in constant touch with the website at that time. I only noticed it on the website after my letter dated 19th June 2012 to the Director General.

8. Misleading information in the Inspector’s reports
See 1. and 3. above
Also, we do not see how “The upstream and downstream monitoring data submitted with the application for the Blessington WWDL indicates that the River Liffey complies with the Environmental Objectives (Surface Water) Regulations” and that “the upstream monitoring data (approximately 110m upstream of the primary discharge point) submitted with the Ballymore Eustace WWDL application indicates that the River Liffey at this point does not comply with the Environmental Objectives (Surface Water) Regulations 2009.”  There are only a few hundred metres between Golden Falls Power Station and Ballymore Eustace Liffey Bridge. The only major discharge into the Liffey between these two points is from Dublin City Council’s Water Treatment Plant which to our knowledge does not contain either phosphates or ammonia and has been investigated by the EPA in the past. (EPA Office of Environmental Enforcement Site Investigation Report dated 24th July 2006). Our concern about Dublin City Council’s discharge relates to Aluminium, Polyelectrolyte (FLOPAM 4140P supplied by Chemifloc Ltd.) and Suspended Solids.

9. Request to reduce the emission limit value set for ammonia in the Blessington WWDL.
See 3 above.

10. Ballymore Eustace Monitoring Data
We do not feel the reply given adequately explains the difference in water quality expressed in the Inspector’s Report for the Blessington WWDL and the Inspector’s Report for the Ballymore Eustace WWDL. Neither does it answer Wicklow County Council’s claim that “The data used by the EPA in the Assimilative Capacity Report referenced by the Anglers’ Association was from urban waste water returns (upstream and downstream of Ballymore Eustace Waste Water Treatment Discharge). It is the Council’s understanding that this data was generated from staff in the local Waste Water Treatment Plant using basic equipment. The Council would feel that this data should not have been used by the E.P.A. in their report considering that there were existing National Monitoring Stations upstream and downstream for which reliable data is available. The data from these stations and the results are far more reliable (see attachment) and compare well with the County Council data below the Golden Falls dam for the same period. There were a number of outlying results which caused averages to elevate but the results from 2007-2009 confirmed good physiochemical status at Ballymore Bridge.”

As stated previously, the Ballymore Eustace Trout and Salmon Anglers’ Association are for the most part pleased with the provisions of the WWDL for both Ballymore Eustace and Blessington. However, we are left high and dry as to the cause of the algae growth in the River Liffey in the early part of each angling season which no one wants to know or do anything about. If it wasn’t for the ESB releasing generation flood waters, the Liffey at Ballymore Eustace would be unfishable and aesthetically unpleasant.

Yours sincerely,
___________________________
Thomas Deegan
Honorary Treasurer.