Filamentous Algae, Liffey

Filamentous Algae Pollution of the River Liffey upstream of  Ballymore Eustace Bridge 9th May 2014






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.V 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
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 Service
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
Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare.
7th May 2013

OEE Water (Wexford) Team B
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.

Ref: D0063-01/D0063-01 27032013 response to Complaint.docx

Dear Sir/Madam,

I refer to letter dated 25th April 2013 from the Director of Services, Water & Environmental Services, Wicklow County Council in connection with the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake/Reservoir and algae growth in the River Liffey at Ballymore Eustace. S.I. 272 of 2009 Schedule 5 of the EUROPEAN COMMUNITIES ENVIRONMENTAL OBJECTIVES (SURFACE WATERS) REGULATIONS 2009 sets the conditions for calculating surface water ecological status and ecological potential for ammonia as follows;

Total Ammonia mg N/l, Good status ≤0.065 (mean) or ≤0.140 (95%ile). For the months of February, March, April 2012 (i.e Spring growth season) the Golden Falls Lake (mid-lake sample) the ammonia mean is 0.135 mg/l N or double the good status criteria.

For the months of February, March 2013(no April figures supplied) the Downstream (Golden Falls Dam sample) the ammonia mean is 0.147 mg/l N or over double the good status criteria.

For the whole period January 2012 to March 2013 for both sample locations the ammonia 95%ile results (0.188 & 0.154 mg N/l) exceeds the good status maximum of 0.140mg N/l.

Given the above figures we are at a loss to understand how Wicklow County Council can state “The results show that the quality of the water at both locations is at GOOD STATUS. This is clearly not the case and the EPA should make Wicklow County Council aware of their misinformation. Also, both ammonia and phosphorus are listed in Schedule 5 of S.I. 272 of 2009 under the heading “NUTRIENT CONDITIONS” so how can Wicklow County Council rule out ammonia as a cause of algae growth in the Liffey. Wicklow County Council never mentioned problems with ammonia discharges to Golden Falls until the Association graphically highlighted by letter dated 29th May 2012 (enclosed) the high concentrations in the Golden Falls Lake and the down stream water samples which coincides with the algae growth in the Liffey at Ballymore Eustace. As the following graph highlights, the Blessington WWTP discharge can raise the baseline ammonia concentration in Golden Falls Lake and the Liffey downstream by a multiply of 19. Wicklow County Council’s response is “In order to achieve compliance it will be necessary to carry out a costly upgrade of the treatment facilities.” If they had been monitoring results they would have been aware of the high ammonia concentrations and the upgrade would have been included as part of the 2007 work.

Graph based on ammonia results from Wicklow County Council’s Appendix A figures.

I have enclosed photographs taken on the 1st May 2013 of the algae covering the gravel bed and also floating on the surface of the River Liffey at Ballymore Eustace.

Yours sincerely,
____________________________
Thomas Deegan
Honorary Treasurer
Copy; Mr. Bryan Doyle, Director of Services, Water and Environmental Services.
ENCL.

Filamentous Algae covering gravel bed of Liffey upstream of Ballymore Bridge 1st May 2013

Digital StillCamera

Digital StillCamera

Digital StillCamera

Digital StillCamera


Filamentous Algae floating on surface of Liffey 1st May 2013

Ballymore Eustace Trout and Salmon Anglers' Association,
Broadleas,
Co. Kildare.
27th May 2013
OEE Water (Wexford) Team B
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.
Ref: D0063-01/D0063-01 27032013 response to Complaint.docx

Dear Sir/Madam,

Previous correspondence also applies

. Filamentous algae is seriously diminishing the aesthetic and recreational value of the River Liffey at Ballymore Eustace.

Please find enclosed the result of a simple Google search relating to filamentous algae.

It confirms our opinion that the filamentous algae is caused by nutrients from the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake, just upstream of Ballymore Eustace village.

Yours sincerely,

_____________________________ Thomas Deegan
Honorary Treasurer
Copy; Mr. Bryan Doyle, Director of Services, Water and Environmental Services, Wicklow County Council.
ENCL.
Four extracts from various Google articles dealing with Filamentous Algae.
Extract 1.
Oilgae is the definitive resource for algae energy. In addition to being an online hub for all aspects of algae energy, the Oilgae team is also a regular contributor to various online and offline forums. The Oilgae team members have also been invited to speak and present at numerous international conferences and seminars.
Filamentous Algae - Filamentous (green) algae, often called “moss” or “pond scum,” are characterized by long, hair-like strands, or filaments, of attached cells (often reaching two metres in length). Filamentous green algae respond to dissolved nutrients, especially nitrogen, with increased growth and reproduction.
Extract 2.
Controlling Filamentous Algae in Ponds
William E. Lynch Jr.
Program Specialist, Aquatic Ecosystem Management
School of Environment and Natural Resources
The most common aquatic plant problem in Ohio is filamentous algae. Its presence can degrade water quality and recreational enjoyment. Excessive algae can cause oxygen depletion when it decomposes as a result of natural die-off or an algaecide application. This is often the cause of a fish kill, depending on how low oxygen levels get. Early and regular control measures will help reduce the problems associated with filamentous algae.
The Plant
Filamentous algae, also called “moss” or “pond scum,” forms dense mats of hair-like strands. Its growth begins on submerged objects on the pond bottom. As it grows, algae produce oxygen that becomes entrapped by the denseness of the mat. This provides the buoyancy it needs to rise to the surface where it frequently covers large areas of the pond. Filamentous algae is often a persistent problem because it reproduces rapidly by fragments, spores, and cell division. Abundance is dependent on nutrient levels, particularly phosphorus, in the water. High levels of nutrients result in increased amounts of algae.
Extract 3.

Preventing Filamentous Algae Problems Any overabundant plant growth is a symptom of excessive nutrients (phosphorus and nitrogen) in the pond water.
Extract 4.
How do I control filamentous algae?
Use Integrated Pest Management...
1. Prevention: The only way to prevent chronic regrowth of algal mats is to reduce the nutrients washing into the pond.
More Photos taken on 15th May 2013
Filamentous Algae floating on surface of Liffey at Ballymore 15th May 2013
Filamentous Algae floating on surface of Liffey at Ballymore 15th May 2013
Filamentous Algae on gravel and floating on surface of Liffey at Ballymore 15th May 2013
WICKLOW COUNTY COUNCIL
Water & Environmental Services
County Buildings
Mr. Thomas Deegan,
Ballymore Eustace Trout & Salmon Anglers' Association
Broadleas,
Ballymore Eustace,
Co. Kildare
13th June 2013

Dear Mr. Deegan,

I refer to your letter dated 7th May 2013 addressed to the Environmental ProtectionAgency and reply to tree points in the order in which they were raised: -

1. That part of the letter on page 1 starting at "Given the above figures...' For GOOD status the ammonia should meet either 95°/o ile or the Mean values. The 95%ile or the Mean calculation should be based on a representative number of samples. The two samples (March and February) cited in the letter could not be considered representative in determining status.

The mean value calculation for ammonia for the period from January 2012 to March 2013 for samples taken downstream of the discharge are as follows:

Midpoint of the Golden Falls lake = 0.06 mg/1 - N. Golden Falls Dam = 0.058 mg/1 - N.

Both are below 0.065 mg/1 - N, which is the mean value attributed to GOOD status.

Whereas it is true to say that there are certain periods where elevated ammonia concentrations have been recorded, the overall monitoring results indicate a GOOD status for ammonia in the river.

2. That part of the letter on page 1 starting at "Also, both ammonia and phosphorus..."

This point in relation to ammonia is addressed in Item 1 above.

3. That part of the letter on page 2 starting at "Wicklow County Council never mentioned..."

In 2007, the Waste Water Discharge (Authorisation) Regulations 2007 came into force, which required that all discharges from wastewater treatment plants be licenced by the Environmental Protection Agency. Blessington received its licence (registered number D0063-01) on 12th June 2012. The Blessington 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 all of the parameters - with the exception of ammonia. This was explained in previous correspondence.

Therefore, ammonia becomes a problem from the date the Discharge Licence was issued because the Licence states an Emission Limit Value for ammonia that cannot be complied with having regard to the current treatment facilities at the treatment plant.

Environmental Protection Agency

The Environmental Protection Agency has requested the following:

"Wicklow County Council shall fully investigate this matter and if it finds that the matter is not as a result of the discharge from Blessington WWTP, Waste Water Discharge Licence No. D00063-01, you shall ensure that the matter is referred to the appropriate section of Wicklow County Council to ensure the matter is investigated and resolved satisfactorily.

Written records on the actions taken to resolve this Complaint should be kept in accordance with the conditions of your Licence or Certificate. These records may be subject to inspection by the EPA during audits and in the event that the Complaint issue is not addressed copies of these records may be requested by the EPA as part of any follow up enforcement action.

You are also required to directly contact the Complainant as outlined above to advise them on how and when this matter will be resolved. In addition, the licensee shall respond to the Agency to report on findings of the investigation and to detail actions to be taken to close out this complaint satisfactorily"

An inspection of the river Liffey was carried out on 14th May 2013 by Wicklow County Council's Environmental staff at two locations (approximately 500m upstream of Ballymore Bridge and at approximately 250m downstream of Ballymore Bridge).

It was found that the bed of the river was covered in a growth of a fragile filamentous algae, that, in turn, was heavily coated with a dark organic looking silt.

There was a riffle area 500m downstream of the Bridge and this was free from the filamentous algae - presumably due to faster flow.

The algae was very fine, but looked much bigger than it actually was due to the fine silt attached.

The algae was examined under the microscope but nothing in particular was identified and the cause of this type of sediment could not be identified.

Conclusion

The river Liffey immediately downstream of the Blessington discharge point, including that part of the river where the algae problem is occurring, is in Co. Kildare.

It is not possible for Wicklow County Council to monitor discharges downstream of the discharge point, which is outside of its administrative area.

Therefore, Wicklow County Council would not be aware any other discharges to the river Liffey downstream of the Blessington discharge. Drawing number 0247/10 (enclosed) shows the relative locations of the Blessington discharge SW1, the Golden Falls Lake (also referred to as reservoir), and the Wicklow/Kildare boundary.

It is readily admitted that the treatment facilities at Blessington wastewater treatment plant are not sufficient to meet the discharge Emission Limit Value requirements for ammonia as stated in the Discharge Licence D0063-01).

Looking solely at the Blessington discharge, the resolution would be for this discharge to achieve full compliance with the Discharge Licence D0063-01 requirements - particularly in respect of ammonia.

In that regard Wicklow County Council submitted a formal application to the Department of the Environment Community and Local Government earlier in 2013 seeking their approval for, and funding of, the proposed upgrade works (in accordance with the Department's Water Services Investment Programme).

As a result of the proposed upgrade works the discharge will achieve compliance in respect of ammonia.

The Council awaits the Departments response to the application.

Yours sincerely,
Bryan Doyle
Director Services,
Water & Environmental Services.
cc (via EDEN):
OEE Water (Wexford)
Office of Environmental Enforcement, Environmental Protection Agency,
PO Box 3000, Johnstown Castle Estate, Co. Wexford
Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare.
1st July 2013
OEE Water (Wexford) Team B
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.
Ref: D0063-01/D0063-01 27032013 response to Complaint.docx

Dear Sir/Madam,

Previous correspondence also applies.

The above Association wishes to make the following reply to the letter dated 13th June 2013 received from the Director of Services, Water and Environmental Services, Wicklow County Council as a result of a request by the Environmental Protection Agency that Wicklow County Council fully investigate the pollution of the Liffey by filamentous algae resulting from the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake.

As we stated in our letter dated 7th May 2013 S.I. 272 of 2009 Schedule 5 of the EUROPEAN COMMUNITIES ENVIRONMENTAL OBJECTIVES (SURFACE WATERS) REGULATIONS 2009 sets the conditions for calculating surface water ecological status and ecological potential for ammonia as follows; Total Ammonia mg N/l, Good status ≤0.065 (mean) or ≤0.140 (95%ile). For the months of February, March, April 2012 (i.e Spring growth season) the Golden Falls Lake (mid-lake sample) the ammonia mean is 0.135 mg/l N or double the good status criteria.

For the months of February, March 2013 (no April figures supplied) the Downstream (Golden Falls Dam sample) the ammonia mean is 0.147 mg/l N or over double the good status criteria. Again, as we stated in our letter of the 7th May 2013 we only had figures for these months as the April figures were not supplied to us.

For the whole period January 2012 to March 2013 for both sample locations the ammonia 95%ile results (0.188 & 0.154 mg N/l) exceeds the good status maximum of 0.140mg N/l.

We now request Wicklow County Council, in accordance with Condition 6.6 of the Blessington Discharge Licence to put up all the monitoring results of the WWTP discharge and Golden Falls Lake on a dedicated section of Wicklow County Council’s website so that we can obtain up to date environmental information relating to the Blessington WWTP discharge into Golden Falls Lake. (Condition 6.6: The licensee shall establish and maintain a Public Awareness and Communications Programme to ensure that members of the public can obtain, at all reasonable times, environmental information relating to the discharge.)

We disagree with Wicklow County Council that “Therefore, ammonia becomes a problem from the date the Discharge Licence was issued because the Licence states an Emission Limit Value for ammonia that cannot be complied with having regard to the current treatment facilities at the treatment plant.” Regardless of an Emission Limit Value for ammonia set in the Licence, ammonia was a problem as soon as it caused pollution of the Liffey at Ballymore Eustace and further downstream. If nutrients, of which ammonia is but one part, still causes pollution of the Liffey in the form of filamentous algae after the Emission Limit Value of 5mg/l is achieved by Blessington WWTP, the Association will be seeking a lower ELV when the Blessington discharge licence is being reviewed. If Wicklow County Council had been listening to our complaints over the years they would have known that the Blessington WWTP discharge to Golden Falls Lake was polluting the Liffey downstream and the slightest research into filamentous algae would have concluded that nutrients were the cause of the pollution.

In November 1984 (Ref 295/84) Kildare County Council gave Wicklow County Council permission to lay a 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.

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.” The Association is 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. However, when the Association informed Wicklow County Council of the Inspector’s report, Wicklow County Council’s response was 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.”

When Wicklow County Council upgraded the Blessington WWTP in 2007 they only concentrated on one half of the nutrient discharge, namely phosphorus. When my Association continued to point out the pollution of the Liffey at Ballymore Eustace, I was told by letter dated 23rd May 2012 “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.”

It is evident that Wicklow County Council response is to blame others. (A recent court case involving Wicklow County Council also shows their reluctance to accept blame.)

With regard to the inspection of the river Liffey on the 14th May 2013 this is another attempt to confuse the issue with “a dark organic looking silt.” Is this an attempt to blame the discharge from the Dublin City Council’s Water Treatment Plant for the problem? Unfortunately for Wicklow County Council the filamentous algae is present upstream of the DCC discharge. Also, since the algae forms on the bed of the river before floating to the surface, you would expect it to contain silt. However, since it was raised, the Association request Wicklow County Council to provide us with the annual weight of suspended solids discharged into Golden Falls Lake from Blessington WWTP and could this account for the “dark organic looking silt.”

With regard to “a riffle area 500m (sic) downstream of the Bridge and this was free from the filamentous algae – presumably due to faster flow” again, this was a wrong conclusion on the part of Wicklow County Council. The slightest local enquiry would have revealed that this was caused by Ward and Burke Contractors digging up the bed of the river to lay an overflow pipe from the new pumping station being constructed by Kildare County Council.

The Conclusion at the end of the Wicklow County Council letter is an attempt to wash their hand of the pollution of the Liffey at Ballymore Eustace and confirms our opinion that the discharge from Blessington WWTP should never have been allowed into Golden Falls Lake. It is similar to a neighbour from hell spilling rubbish into your garden and expecting you to remove it and clean it up. In keeping with the polluter pays principle Wicklow County Council have a number of options including (a) admit that nutrients from the Blessington WWTP discharge into Golden Falls Lake is the cause of the filamentous algae pollution of the Liffey at Ballymore Eustace and further downstream, and make every effort to remedy the problem in a speedy manner. (b) They can ask Kildare County Council to monitor the discharges downstream of the Blessington WWTP discharge and pay Kildare County Council’s costs or (c) they can seek permission from Kildare County Council for Wicklow County Council to carry out the monitoring. They already take samples from mid Golden Falls and Golden Falls Dam, both locations outside their administrative area.

Yours sincerely,
_____________________________
Thomas Deegan
Honorary Treasurer
Copy; Mr. Bryan Doyle, Director of Services, Water and Environmental Services, Wicklow County Council.
WICKLOW COUNTY COUNCIL
Water & Environmental Services
CountyBuildings
Wicklow
Mr. Thomas Deegan,
Ballymore Eustace Trout & Salmon Anglers' Association
Broadleas,
Ballymore Eustace,
Co. Kildare
18th July 2013
RE: Blessington Wastewater Treatment Plant - D0063-01

Dear Mr. Deegan,

I refer to your letter dated 1st July 2013 addressed to the Environmental Protection Agency and to the following points raised therein: -

1. Page 1 (last paragraph) starting at "We now request Wicklow CountyCouncil..."

The Council maintains a Public Awareness and Communications Programme inrespect of Blessington in accordance with the requirements of Condition 6.6 attached to the Licence. The Public Awareness file contains all monitoring results and is available for inspection at the Council's main offices at County Buildings, Wicklow from 9.00 a.m. to 3.30 p.m. Monday to Friday (excluding public holidays). Also, full monitoring results for 2012 are included in the 2012 Annual Environment Report (AER) for Blessington. The AER may be viewed on the EPA website at: - http://www.epa.ie/terminalfour/wwda/index.jsp

I regret that it is not possible to set up a dedicated site on the Council's website for discharge monitoring data at this time.

2. Page 3 (last paragraph) starting at "When Wicklow County Council upgraded..."

As stated in the Council's previous letter dated 24th April 2013, the Blessington wastewater treatment plant was upgraded in 2007 and met all of the statutory requirements in force at that time. The upgrade works included the provision of phosphate removal facilities.

3. Request on page 4 for the annual weight of Suspended Solids discharged to the receiving waters. The discharge of Suspended Solids in the calendar year 2012 was 5,194 kg Dry Solids. The average Suspended Solids concentration was 15.88 mg/1. The discharge was 327,086 m3.

Conclusion

It is readily admitted that the treatment facilities at Blessington wastewater treatment plant are not sufficient to meet the discharge Emission Limit Value requirements for ammonia as stated in the Discharge Licence D0063-01).

Wicklow County Council is endeavouring to rectify this and submitted a formal application to the Department of the Environment Community and Local Government seeking their approval for, and funding of, the proposed upgrade works (in accordance with the Department's Water Services Investment Programme) in order to achieve compliance with the Discharge Licence.

The Council awaits the Department's response to the application.

Yours sincerely,
Michael Geaney,
A/Director of Services,
Water & Environmental Services.
cc(via EDEN):
OEE Water (Wexford)
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford

Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare.
29th July 2013
OEE Water (Wexford) Team B
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.
Ref: D0063-01/D0063-01 27032013 response to Complaint.docx

Dear Sir/Madam,

Previous correspondence also applies.

The above Association wishes to make the following reply to the letter dated 18th July 2013 received from the A/Director of Services, Water and Environmental Services, Wicklow County Council in response to ours dated 1st July 2013 addressed to the Office of Environmental Enforcement, EPA, and copied to the Director of Services, Wicklow County Council.

In their letter dated 18th July 2013, Wicklow County Council still do not say how they are going to fully investigate the pollution of the Liffey by filamentous algae resulting from the Blessington Waste Water Treatment Plant discharge into Golden Falls Lake as requested by the Environmental Protection Agency. While the Council “readily admitted that the treatment facilities at Blessington wastewater treatment plant are not sufficient to meet the discharge Emission Limit Value requirements for ammonia as stated in the Discharge Licence D0063-01” they cannot bring themselves to admit that the discharge from Blessington WWTP is responsible for the filamentous algae pollution of the Liffey downstream of Golden Falls Lake. When Wicklow County Council upgraded the Blessington WWTP in 2007 they only reduced the phosphate portion of the nutrients in the discharge and not the ammonia/nitrogen. The fact that the discharge continued to pollute the Liffey means that the discharge did not then, or now, meet all statutory requirements. Under section 171 of the Fisheries (Consolidation) Act 1959 any person who “(b) throws, empties, permits or causes to fall into waters any deleterious matter” is guilty of an offence.

It is not acceptable that the Public Awareness and Communications Programme file is only available at the County Building in Wicklow which is the opposite side of the County to where the Blessington WWTP discharges and the resultant pollution of the Liffey in County Kildare occurs. Members of the Association, or public, cannot be expected to travel from County Kildare to the other side of Wicklow during office hours every time they want to access monitoring results from the Public Awareness file. Does Wicklow County Council really expect us to waste all this time, energy, money, not to mention the air pollution and carbon footprint caused in travelling across the County of Wicklow in order to access or view the monitoring data from Blessington WWTP discharge. The Public Awareness file including all monitoring data must be made available at the Blessington WWTP or the Wicklow County Council offices in Blessington. Also, in this day and age, it certainly is possible to set up a dedicated site on Wicklow County Council’s website.

Yours sincerely,
_____________________________
Thomas Deegan
Honorary Treasurer
Copy; Mr. Bryan Doyle, Director of Services, Water and Environmental Services, Wicklow County Council.

WICKLOW COUNTY COUNCIL
Water & Environmental Services
Aras An Chontae / County Buildings
Chill Mhantain /Wicklow County Council
Mr. Thomas Deegan,
Ballymore Eustace Trout & Salmon Anglers' Association
Broadleas,
Ballymore Eustace,
Co. Kildare
7th August 2013
RE: Blessington Wastewater Treatment Plant - D0063-01

Dear Mr. Deegan,

I refer to your letter dated 29th July 2013 addressed to the Environmental Protection Agency and to the following points raised therein: -

1. Investigate filamentous algae.

Wicklow County Council carried out an investigation in May 2013 and a report was included in our previous letter dated 13th June 2013. The results of the investigation were inconclusive.

2. Statutory requirements.

Notwithstanding the legislation quoted in your letter, there are specific statutory requirements governing wastewater discharges.

As stated in the Council's previous letters, the Blessington wastewater treatment plant upgrade, carried out in 2007, met all of the statutory requirements in force at that time.

3. Public Awareness and Communications Programme

The Council has taken your suggestion on board and will arrange to have a file made available for inspection at its Blessington Area office during office hours starting on 1st September 2013.

This file will contain all environmental monitoring information as required by the Licence including Influent, Effluent and Ambient monitoring summary results.

The file will also contain copies of the Annual Environment Reports and a copy of the Licence D0063-01.

The Blessington Area office address is Blessington Civic Offices, Blessington BusinessPark, Blessington, Co. Wicklow. Their phone number is 045-891222. Their officehours are from 9:00 a.m. to 5:00 p.m. Monday to Friday (excluding public holidays).

The office is closed for lunch from 1:00 p.m. to 2:00 p.m.

The main Public Awareness and Communications Programme file will remain available for inspection at the Council's main offices at County Buildings, Wicklow.

Yours sincerely,
Bryan Doyle
Director of Services, Water & Environmental Services.
cc (via EDEN):
OEE Water (Wexford)
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford
Environment Section,
Aras Chill Dara,
Devoy Park,
Naas,
Co. Kildare
09/08/2013
Re: Ballymore Eastace_diffuse pollution _algae- PAE2013/101.

Dear Ms. Greene,

The Agency has received a number of complaints regarding filamentous algae in the vicinity of Ballymore Eustace bridge from the Ballymore Eustace Trout and Salmon Angler's Association. The complainants assert mat the source of the pollution is the wastewater treatment plant operated by Wicklow County Council that discharges upstream of Golden Falls lake. The EPA's licensing enforcement section requested Wicklow Co Co to carry out investigations, the results of which indicate that it is not the cause of the filamentous algae.

In light of these findings, Kildare County Council is requested to investigate diffuse sources and other point sources within the catchment of Golden Falls lake, utilising all appropriate enforcement action as necessary in line with the National Complaints procedure. The investigation team should liaise directly with Wicklow County Council in order to resolve this issue.

Your Council is also requested to directly contact the Ballymore Eustace Trout and Salmon Angler's Association in relation to this matter and to advise them that Kildare County Council is investigating and dealing with the complaint.

It would be appreciated if Kildare County Council would provide a report to the Agency on the outcome of its investigations into this matter for our files upon its completion.

The EPA person dealing with this file is Margaret Keegan to whom all correspondence and queries in relation to the matter should be addressed.

Please use the reference number above in all future communications with the OEE regarding this matter.

Yours sincerely,
Margaret Keegan
Office of Environmental Enforcement
CC Mr. Thomas Deegan, Ballymore Eustace Trout and Salmon Anglers Association
Mr. Brian Doyle, Director of Services, Wicklow County Council
Ms. Becci Cantrell, Licensing Enforcement

Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare.
23rd August 2013
OEE Water (Wexford) Team B
Office of Environmental Enforcement,
Environmental Protection Agency,
PO Box 3000,
Johnstown Castle Estate,
Co. Wexford.
Ref: D0063-01/D0063-01 27032013 response to Complaint.docx

Dear Sir/Madam,

Previous correspondence also applies.

The above Association wishes to make the following reply to the letter dated 7th August 2013 received from the Director of Services, Water and Environmental Services, Wicklow County Council in response to ours dated 29th July 2013 addressed to the Office of Environmental Enforcement, EPA, and copied to the Director of Services, Wicklow County Council. In a letter addressed to the Association dated 13th June 2013 the Director of Services informed us that the Environmental Protection Agency had requested the following:

“Wicklow County Council shall fully investigate this matter and if it finds that the matter is not as a result of the discharge from Blessington WWTP, Waste Water Discharge Licence No. D00063-01, you shall ensure that the matter is referred to the appropriate section of Wicklow County Council to ensure the matter is investigated and resolved satisfactorily.

Written records on the actions taken to resolve this Complaint should be kept in accordance with the conditions of your Licence or Certificate. These records may be subject to inspection by the EPA during audits and in the event that the Complaint issue is not addressed copies of these records may be requested by the EPA as part of any follow up enforcement action.

You are also required to directly contact the Complainant as outlined above to advise them on how and when this matter will be resolved. In addition, the licensee shall respond to the Agency to report on findings of the investigation and to detail actions to be taken to close out this complaint satisfactorily”

In his letter dated 7th August 2013 the Director of Services tells us under the heading

“1. Investigate filamentous algae.

Wicklow County council carried out an investigation in May 2013 and a report was included in our previous letter dated 13th June 2013. The results of the investigation were inclusive.”

If Wicklow County Council consider that the “inspection of the river Liffey carried out on the 14th May 2013 by Wicklow County Council’s Environmental staff at two locations ---” constitutes a full investigation as requested above by the Environmental Protection Agency then in our view there is no wonder we have a filamentous algae pollution problem in the Liffey at Ballymore Eustace.

With regard to the Public Awareness and Communications Programme we are pleased that a file will now be made available for inspection at Wicklow County Council’s offices in Blessington but we will reserve judgement until we see what information is contained in the file and how easy it is to access the file.

Yours sincerely,
_____________________________
Thomas Deegan
Honorary Treasurer
Copy; Mr. Bryan Doyle, Director of Services, Water and Environmental Services, Wicklow County Council.

The Association received the following letter from Kildare County Council
09th October 2013
Environment Section
L. Dunne/D. Keenan
Ballymore Eustace Trout and Salmon Anglers Association
c/o Tommy Deegan, Broadleas,
Ballymore Eustace,
Naas, Co. Kildare.
Re: Ballymore Eastace_diffuse pollution _algae- PAE2013/101.

Dear Mr. Deegan,

I refer to your complaint to the Environmental Protection Agency in respect of the above. I wish to advise that Kildare County Council is investigating the complaint.

Kildare County Council is preparing a report in relation to its investigations and will forward this to the Agency upon its completion. If you require any further information please contact the Environment Section on 045 980588.

Yours sincerely,

D. Keenan
pp Liam Dunne, Senior Executive Officer

The Association replied as follows to ensure that Kildare County Council were fully aware of the extent of the algae pollution of the Liffey at Ballymore Eustace.
Ballymore Eustace Trout and Salmon Anglers’ Association
Broadleas,
Ballymore Eustace,
Co. Kildare,
10th October 2013
Mr. Liam Dunne,
Senior Executive Officer,
Environment Section,
Kildare County Council,
Aras Chill Dara, Devoy Park,
Naas,
Co Kildare.
Re: Ballymore Eustace diffuse pollution algae – PAE2013/101

Dear Mr. Dunne,

Thank you for you letter dated 9th October 2013 in respect of the above. For many years the above Association has been complaining to the Office of Environmental Enforcement, Environmental Protection Agency about the pollution of the Liffey at Ballymore Eustace by filamentous algae caused we believe by nutrients from the Blessington WWTP discharge into Golden Falls Lake upstream of Ballymore Eustace village.

(Some of our letters were copied to the Kildare County Manager)

Most of the correspondence to date can be viewed on our website www.kildare.ie/ballymoreanglers (Click on TSAA news and Filamentous Algae)

Some of the logos etc did not scan to our website and graphs that we included with some letters also did not scan. For this reason I have enclosed letters with graphs. I have also enclosed photographs which were sent to the OEE and which I hope to copy to the website as soon as possible and a short Google search on filamentous algae.

I hope that these may help in your investigation.

Yours sincerely,
________________________________
Thomas Deegan
Hon. Treasurer
ENCL
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