In 2013, the Environmental Protection Agency (EPA) established the National Inspection Plan for Domestic Waste Water Treatment Systems. The National Inspection Plan (NIP) sought to encourage the correct management of domestic wastewater treatment systems (DWWTSs) throughout Ireland by means of an annual allocation of septic tank system inspections in areas acutely vulnerable to contamination, and an extensive citizen-engagement strategy. It was proposed by the EPA that the plan’s instigation would help minimise the potential for environmental and health impacts stemming from defective DWWTSs.
The NIP has now been in place for over two years and recently entered its second cycle (2015-2017). However, the progress made by the plan thus far is believed by close observers to be insufficient. Only slightly over half of the septic tank systems inspected under the plan in the first year achieved a pass grade and there is evidence to suggest that any wider shift in attitudes and behavioural change among DWWTS users has been marginal at best.
Although the onus is on the relevant public to adhere to their responsibilities and demonstrate good practice, their failure to do evidences several inherent flaws of the NIP that require urgent remediation – in particular, its citizen-engagement strategy.
The ramifications of exposure to untreated domestic wastewater are well documented – especially where effluent is allowed to enter drinking water supplies (e.g., private wells and group water schemes) and public waterways. The resulting contamination of ground- and surface water can engender outcomes such as pronounced environmental degradation, widespread odour disturbance and proliferation of waterborne diseases such as VTEC (a pathogenic strain of E. coli) and cryptosporidium. The appropriate installation and maintenance of DWWTSs is thus vital.
Given the sheer number and volume of DWWTS in Ireland, the risk of contamination is high.
There are currently over 500,000 DWWTSs (predominantly septic tanks) located across Ireland, the majority of which are concentrated in rural Ireland due to its largely dispersed pattern of settlement.
Furthermore, over 80% of Irish households in rural areas treat and dispose of wastewater on-site (accounting for over one third of the national population) with a similarly high percentage also availing an of onsite groundwater source for drinking water. These figures confirm that rural households are potentially a formidable source and receptor of water contamination and underscore the importance of the NIP in potentially reducing this threat.
However, despite the NIP’s questionable performance and the ensuing repercussions, the plan’s implementation has received limited media attention and criticism since its instigation. This can largely be attributed to the pervasive perception of DWWTSs as being a minor, rural-only issue. However, a mounting body of evidence suggests that septic tanks are beginning to constitute a principal cause of water contamination in rural Ireland and play a significant role in the rising number of VTEC cases documented throughout the country.
In order to fully identify and affirm the NIP’s shortcomings, it is necessary to recount the origins and development of the plan.
The NIP was first put forward by the Irish government in 2011 in response to the ruling of the European Court of Justice (ECJ) over Ireland’s longstanding circumvention of its obligation, under the 1975 EU Waste Framework Directive, to properly regulate domestic wastewater generated in unsewered (primarily rural) areas. Ireland had previously been rebuked by the ECJ for the breach in 2009 but the government’s slow pace in initiating an appropriate registration and inspection system for DWWTSs resulted in a second, harsher ruling to which the NIP responded. The inception of the NIP was evidently reactive rather than proactive.
The purpose of the NIP was outlined in the government’s 2012 Water Services (Amendment) Act, which satisfied the ECJ’s criteria. The NIP’s core aspects would be informed by the guidelines set out in the act and the EPA would be given the job of preparing and expanding the plan. In most cases the guidelines were firm and incisive, yet in others they were markedly lenient, neglecting to mention any binding provision for correct DWWTS design and construction or consistent metrics for the NIP. As a result, these facets were given little attention in the finalized plan.
The delivery of the bulk of the NIP was assigned to local authorities, with the EPA acting in a primarily supervisory role. Local authorities would be held responsible for initiating a register of DWWTS, administering the annual septic-tank inspections and overseeing citizen engagement at the local level while the EPA would direct and supervise local authorities, nominate and train inspectors and help instigate citizen engagement at the national level.
The government would meanwhile play a smaller, albeit significant, part by providing funding for the plan, enforcing policy and administering a grant scheme for septic tank repairs for homeowners chosen for local authority inspections.
It was decided by the EPA that a minimum target of 1,000 septic tank inspections would be undertaken each year. The EPA availed of the S-P-R (Source-Pathway-Receptor) model and GIS maps to establish the areas most vulnerable to septic-tank-contamination and subsequently apportioned inspections to each county accordingly.
As to the NIP’s engagement strategy, following a period of consultation with a number of representatives from environmental, farming and rural organisations, the EPA elected to centre citizen engagement on a public information campaign stressing the importance of clean water. To this effect a variety of engagement mechanisms would be used – ranging from informative television segments on a national scale to radio advertisements and school visits at a local level.
The NIP’s engagement strategy was rolled out in early 2013 with inspections beginning on 1 July. Given that the inspections would be situated in high-risk areas, the results of first full year of inspections would act as a useful barometer to gauge the overall progress of the NIP.
Unfortunately, out of the 987 inspections completed between 1 July 2013 and 30 June 2014, only 511 (52%) of septic tanks passed. The failure on the part of EPA and local authorities to encourage a significant shift in the behaviour of septic-tank owners living in the areas most predisposed to contamination represented a disappointing blow and posed worrying connotations as to the broader, national level of behavioural change attained.
The inspection results can be attributed to several questionable policies. For instance: the grant scheme for system repairs only catered for septic-tank owners who had registered as a DWWTS user before 1 February 2013 and consequently would have greatly reduced the inclination for septic-tank owners who had not registered by that date to properly maintain or remediate their septic tank on their own initiative. However, the NIP’s citizen engagement strategy must ultimately shoulder the bulk of the blame as it has patently failed to adequately communicate the degree of risk and provide adequate information regarding septic-tank maintenance.
When formulating a citizen engagement strategy and appended public information campaign, it is imperative to take account current public attitudes and knowledge gaps. By discerning the proclivities of the target public a baseline can be established, providing scope for how the requisite information might or might not be best communicated. If this information is subsequently transmitted to the audience in a manner sympathetic towards or conscious of their stance, the likelihood of compliance will be maximised. In the case of the NIP’s first cycle (2013-14), there is scant indication that the EPA gave any concerted thought to the existing knowledge gaps and attitudes among ordinary DWWTS users – despite having access to recently accumulated data on the subject.
Shortly before the start of the NIP’s engagement strategy, the EPA became aware of an academic study involving the circulation of survey questionnaires to DWWTS homeowners to ascertain their views regarding all aspects of DWWTS. The survey served as a useful insight into the current attitudes of DWWTS users and pinpointed issues such as: a lack of consistency concerning desludging, a lack of information outlining system maintenance and a belief that recent DWWTS legislation was motivated by EU compliance and government revenue rather than protection of human health and the environment. The study was published online in 2013 and funded by the EPA which commissioned the authors to devise and disseminate a further set of similar questionnaires midway through the first year of the NIP’s instigation.
The second set of questionnaires would serve to indicate the degree of change accomplished by the NIP’s engagement strategy so far. However, regrettably for the EPA, the questionnaire results registered only a marginal (6%) increase in support for DWWTS regulations and a similar increase in the amount of respondents who claimed that they had received DWWTS maintenance information.
The results also indicated a stasis in attitudes pertaining to desludging which, tellingly, was the main reason for failure among septic tank inspections according to the EPA. Further scepticism of the NIP’s engagement strategy could be accrued by reading the EPA’s reports on the progress of the plan, which contain a palpable lack of detail and suggest the inconsistent use and application of engagement mechanisms by local authorities.
To the EPA’s credit, the proposed measures for the second cycle of the NIP (2015-17) have placed a more considered focus on citizen engagement.
The EPA has recently established a working group comprising a number of representatives from relevant organisations such as the Health Service Executive (HSE) and the National Federation of Group Water Schemes (NFGWS) in attempts to compose a better-organised, holistic citizen engagement. The EPA has also introduced a metric that determines compliance by tracking the collection of DWWTS sludge by waste collectors.
These recent measures represent a step in the right direction and a concerted effort to improve the NIP’s efficacy. However, these steps must by followed by discernible results. With the Minister of the Department of Environment and Local Government’s recent announcement that the NIP will be reviewed at government level in early 2016, it is clear that the NIP will be thrust into the spotlight again sooner rather than later. •
The risk posed by domestic wastewater treatment systems to human health in Ireland
The ramifications of exposure to untreated domestic wastewater are well documented – especially where effluent is allowed to enter drinking water supplies (e.g., private wells and group water schemes) and public waterways. The resulting contamination of ground- and surface water can engender outcomes such as pronounced environmental degradation, widespread odour disturbance and proliferation of waterborne diseases such as VTEC (a pathogenic strain of E. coli) and cryptosporidium. The appropriate maintenance and regulation of domestic wastewater treatment systems (DWWTSs) is thus vital.
In the case of Ireland, there is a mounting body of recently conducted research that suggests that many DWWTSs across the country have been incorrectly installed or maintained and pose a very real and widely experienced threat to human health.
A 2005 study undertaken by Trinity College, Dublin of 74 randomly located septic-tank systems in Leinster revealed that only 5% were situated in soil conditions conducive to adequate wastewater treatment and indicated the likelihood of similar figures elsewhere in Ireland. The prevalence of such systems was confirmed five years later by the EPA, who discovered that approximately 25,000 DWWTSs in Ireland posed a risk to groundwater while approximately 120,000 posed a risk to surface water.
A study carried out by Trinity College researchers between 2008 and 2010 analysing the quality of groundwater in 262 private wells discerned that DWWTSs posed the greatest contamination hazard for private wells in rural Ireland. The study identified septic tank location as a significant factor towards the occurrence of VTEC in private wells. The brisk exacerbation of this threat could be attributed to a combination of a longstanding lack of regulatory enforcement regarding private well and septic-tank siting and a glut of poorly constructed one-off rural dwellings built during the 2000s decade.
Tellingly, a year after the completion of the Trinity College study in 2011, the Health Protection Surveillance Centre (HPSC) reported a sharp surge in VTEC cases in Ireland, with 37% linked to exposure to a private well. The overall national VTEC incidence rate recorded the same year was almost eight times higher than the EU average and the number of annual cases has since continued to rise.
It is likely that the increased promulgation of such evidence outlining the causal link between the growing frequency of episodes of water contamination and disease and defective DWWTS in Ireland, would result in a more rigorous scrutiny and media coverage of DWWTS maintenance and regulation throughout Ireland. Nevertheless, much of this data remains largely unpublicised.
