Clonshaugh Sewage Plant Submission Aodhán Ó Ríordáin TD,Dublin Bay North

Dear Project Manager,

I wish to make the following observations about the proposal to build a Sewage Plant in Clonshaugh. I believe that the proposal to build such a plant is aesthetically and economically flawed and will impact negatively on the local environment.

The idea that a plant 4 times the size of Croke Park will be put within a one mile radius of 2,500 homes in Clonshaugh is, I believe, a mistake. Furthermore, when you factor in the greater surrounding area then up to 8,000 homes will be affected by this proposal.

I have broken my submission into several sub headings below and I would ask you to them into consideration as part of the submission process.

1) Conservation:

The area around the Baldoyle Estuary is a designated area of conservation. Tunnelling a sewage pipe through this terrain surely violates that status? Previous proposals to build a footpath in that area were opposed by the National Parks and Wildlife Service and ultimately not implemented by Fingal Co. Co. If a path was not suitable, why is a sewage pipe?

Baldoyle Bay is of high conservation importance. There is an important population of Brent Geese, and populations of a further seven species, which according to Fingal County Council are of international and national importance. Furthermore, there is a Statutory Nature Reserve at the inner estuarine section which is a designated wetland under the Ramsar Convention.  I have included below a piece from the Council’s own website which states that planning authorities are obliged by law to ensure that sites such as this are protected and conserved.

The Fingal Coutny Council website also states that:

Special Areas of Conservation in Fingal include Rogerstown and Malahide Estuaries, Baldoyle Bay, North Dublin Bay, Howth Head and coastal habitats on Lambay Island and Ireland’s Eye. All sites in Fingal are now candidate Special Areas of Conservation (cSAC) and full legal protection applies to these sites because the designation process has commenced. Planning authorities are obliged by law to ensure that these sites are protected and conserved.

2) Secondary Treatment:

The plant will be treating sewage only to a secondary, and not tertiary, level and this is unacceptable. Such a treatment, as a last stop treatment before discharge, is an outdated practice. Any treatment which will later be discharged into the sea should be treated to tertiary level to minimise any potential odour and environmental problems.  I believe this is a key flaw in the project’s plans.

3) Several Smaller Plants:

There is a need to look at this project from a panoramic viewpoint. The installation of several smaller treatment plants scattered across various locations in North Dublin is more desirable, more practical and potentially more cost effective. It is the option preferred by local residents’ groups and one which I support.  I would request that at a minimum a cost benefit analysis of such a proposal be carried out by the project team.

4) Local Tourism & Jobs:

There will be a huge environmental impact if there is a discharge of secondary waste into the sea off the coast of Baldoyle.  This has potential to impact on local tourism and the local economy in the areas of Howth, Sutton and Baldoyle. The odour and impact on the scenery will be detrimental and damage local jobs and local business.

Additionally the site is only 2 kilometres from the airport and could impact on any future developments of the Metro North project.

5) Consultation:

As an elected representative I would also like to raise concerns about how local residents were consulted. The plant’s site was chosen by Fingal County Council despite the fact that many of houses within the immediate radius are within the Dublin City Council Local Authority Area.  A lot of these people were not consulted about the process and I think that is completely unfair. It seems misguided that such a decision was taken by only one local authority and not done on a cross jurisdiction basis, given that the waste will be coming from DCC and other surrounding areas and counties.