The EU Water Framework Directive (WFD) sets a requirement to meet ‘Good Status’ in all water bodies by 2015. Where it is not possible to achieve Good Status by 2015 for reasons of technical feasibility or disproportionate costs, Member States may extend the deadline for compliance, setting a less stringent objective in the interim, as long as the reasons are specifically laid out in the River Basin Management Plan (RBMP). However, a condition of extending the deadline is that no further deterioration is permitted in the water body. Within the first cycle RBMPs, the objective for Inner Belfast Lough was to achieve moderate status by 2015, while making progress to good status by 2027. Although the 2015 classifications was moderate overall, there were concerns during the first cycle that the dissolved inorganic nitrogen loading is largely attributed to the discharges from wastewater treatment works (WwTWs) – and combined sewer overflows from the sewerage infrastructure. It is estimated that together, these make up 50% of the overall loading of DIN to Inner Belfast Lough alone. Northern Ireland Environment Agency (NIEA) has warned of the risk of EU infraction proceedings being initiated. The WFD also includes Shellfish Water Protected Areas which must be protected and improved to contribute to the high quality of shellfish products harvested for human consumption from licensed aquaculture beds. All Shellfish Water Protected Areas must be managed to ensure that they meet their objectives under WFD and meet at least Class B status under the EU Hygiene Regulations (for food). Again, sites must be managed to ensure no deterioration. In recent years, there is concern at the regularity in Class C samples in the inner two Representative Monitoring Points (RMPs) 1 and 3. In 2017, the beds related to RMP1 have been downgraded to an Annual Class C, which is deterioration in class.
The sewerage networks and wastewater treatment works serving Belfast are also nearing capacity and need significant upgrades to facilitate future growth and development. Current estimates indicate that without significant upgrades, there is a risk that NI Water may not be allowed to permit some new connections in Belfast from 2021. It is therefore unlikely that Belfast City Council’s proposed Local Development Plan can be implemented without significant parallel investment in drainage & wastewater treatment.
While there is already considerable joint working by the various organisations working to address flooding problems and improve/protect water quality in the environment there is as yet no agreed cross-department infrastructure plan at a strategic level to support economic growth, provide for the long term management of flood risk and improve water quality in the wider environment. In July 2014 the Northern Ireland Executive agreed to set up an interdepartmental group to develop a ‘Strategic Drainage Infrastructure Plan’ (SDIP) for Belfast to protect against flood risk, enhance the environment and support economic growth.
The high level aim for the LWWP is to Develop a strategic drainage infrastructure plan that will manage the flooding risk in Belfast, address the risk of infraction proceedings under the Water Framework and Urban Waste Water Treatment Directives in respect of Belfast Lough, and support economic growth.