The Irish Underwater Council is the national governing body for scuba diving and snorkelling in Ireland.  As an organisation we treasure our wild and wonderful marine environment and all of the animals and plants that live in our seas.

Dublin Port Company are proposing to undertake routine maintenance dredging of the port this spring and summer.  The soft sand and mud that is dredged from the port is scheduled to be dumped at the Burford Bank, in the middle of Dublin Bay.  The Burford Bank lies entirely within the new Rockabill to Dalkey Island Special Area of Conservation (SAC), and it is also within the UNESCO Dublin Bay Biosphere Reserve.

Special Areas of Conservation (SAC) are established under the EU Habitats Directive to protect our most vulnerable habitats and animal species.  In this case the SAC has been designated to protect harbour porpoise, our smallest member of the whale and dolphin group.  The Irish Underwater Council strongly objects to the use of a European designated site for wildlife conservation as a waste disposal facility.

Dumping at Sea permits are issued by the Environmental Protection Agency.  The EPA has refused to undertake a review of Dublin Port Company’s dumping at sea permit, which was issued before the SAC was designated.  In cases such as this, the EU Habitats Directive requires that the regulatory authority shall undertake a review and also screen for Appropriate Assessment.  Appropriate Assessment is the specific form of ecological assessment required to provide scientific evidence regarding the impacts of human activities in an SAC.

Furthermore, when Dublin Port Company applied for the current Dumping at Sea permit they informed the public that the permit was required for the period October 2009 to November 2015.  Therefore, any use of this permit in 2016 has not undergone any public consultation.  Our rights with regards decision making for environmental matters are enshrined in the Aarhus Convention, to which Ireland is a signatory.

Finally, the EPA states that, with respect to Dumping at Sea permits, “All permit application documents, correspondence, submissions etc. are  available on the EPA website”.  The EPA has refused to make publically available the Irish Underwater Council’s correspondence relating to the Dublin Port Company’s dumping at sea permit. The EPA appears to have been in communication with the DPC over this issue, but this correspondence has also not been made publically available.  Why won’t the regulatory authority make these documents available to the public?

The Irish Underwater Council fully recognises the necessity to dredge the channels in Dublin Port – it is an essential element of the maintenance of any port.  However, we feel that it is unacceptable that a protected European site be used as an Irish waste dumping ground, particularly when the use of alternative sites further out to sea have not been investigated. The IUC have organised a peaceful on-water flotilla to travel the River Liffey on Sunday April 24th, leaving Dun Laoghaire at 12 noon and travelling to O’Connell Bridge,  to raise awareness of this important issue.