A Letter from Enda Craig of the Carnagarve Group opposed to plans for a Sewage Treatment Plant to be placed at Carnagarve to Gavin Clabby of the Environmental Protection Agency.

To: Mr. Gavin Clabby
Environmental Protection Agency
Co. Cork

Dear Mr. Clabby,
RE: Proposed Moville/Greencastle Sewerage Scheme & the Discharge Licence
Ref: D0212-01

Following our recent conversations I feel compelled to put on record my
concerns in relation to the confusion that exists about two potential discharge licence applications by Donegal County Council. The first application relates to six untreated discharges that have been operational for decades in Moville, Co. Donegal.

This application is referenced as D0212-01 on your website. However, this application has become confused with the proposed Moville/Greencastle Waste Water Treatment Plant (WWTP) for which no application for a discharge licence has been made. This WWTP proposal was passed by ABP in August 2011 and is currently before the High Court for judicial review.

Although the distinction between these two proposals may not be fully appreciated by everyone, the EPA have confirmed the situation to ABP on at least 3 occasions, the last being on 22/07/2011, a copy of which is enclosed. In this letter the EPA clearly state that…

“The Agency has not received a licence application for the Moville/Greencastle
Sewerage Scheme”.

I do understand that this is an unusual and confusing situation but I must highlight that many of the third party submissions displayed against application reference D0212-01 do not actually refer to that particular application.

It is obvious that should DCC want a discharge licence for their proposed WWTP at
Carnagarve, Moville they would have to make a fresh application to the EPA and follow all the necessary associated procedures. Only then could the EPA begin the assessment of any such application.
In light of the confusion that undoubtedly exists I request confirmation on each of
the following five concerns…

1. The EPA discharge licence application reference D012-01 refers to six current
untreated outfalls in Moville, Co. Donegal. It does not relate to the proposal,
currently before the High Court, for a WWTP at Carnagarve, Moville nor to any
of its associated pumping stations or storm tanks.

2. Any application for a discharge licence for the proposed WWTP at Carnagarve,
Moville and/or associated pumping stations and storm tanks will be a new and
separate application which will be assigned a new EPA reference.

3. Any application for and assessment of a discharge licence for the new proposed
WWTP at Carnagarve, Moville and associated pumping stations will follow the
normal application process for such infrastructure.

4. The EPA will not be making any assessment of discharges from the proposed
WWTP at Carnagarve, Moville or any associated pumping stations and storm
tanks until a formal application is received from DCC for those facilities.

5. Due to this unusual and confusing situation and because it would be unreasonable
to expect even those directly affected by this proposal to continually trawl your
website and the media, I request that I be informed by email in the event that the
EPA receive a discharge licence application for the proposed WWTP at
Carnagarve or for its associated pumping stations and storm tanks. I also request
that I be informed if and when any change occurs to application D012-01.

I understand that the five clarification requests above are most irregular but as I have outlined these are unprecedented circumstances.

Yours Sincerely
Enda Craig