In Preparation!
Water QUALITY Topics index.

1. Discussion with EPA

We have liaised with the EPA regarding water quality in Lough Allen for about 2½ years. They have been encouraging, welcoming of voluntary commitment, have taken samples from us and quickly reported on them, shared their surveys and sourced helpful information for us. In December we were asked by them how we felt our foam observations fitted in with their water tests. We took that opportunity to fully refresh our views on what was happening in Lough Allen and prepared a 10 page ‘draft for discussion’. We very much welcomed this opportunity to release some frustration — at the state of the lake and the weather, not the EPA! This was prepared over Christmas, submitted on the 17th of January and followed up by a meeting on the 7th. February.

In this page we refer to the ‘EPA’. In effect we always dealt with one person both by eMail and at our meeting. However, it was clear that he was in dialogue with colleagues and the response presented to us at our meeting was detailed and authored by three members of the EPA. As always we wish to thank them for all their efforts. There is a degree of disagreement between us as regards the degree to which Lough Allen has become polluted. We are convinced that change has occurred in the past few years which has triggered many instances of severe and significant pollution and we pressed for a programme of action to redress this. The EPA are more of the view that this is relatively normal change and reflects a gradual process, widespread across Europe, and possibly associated with global warming. They did not respond to our offer of local help, indicated thay had no role in ‘Protection’, but did agree that some of our methodologies could be valid but needed to be quantified more. This page summarises this narrative largely based on our submission and their written response, but including personal communications where relevant.

Pollution of Lough Allen: Submission to the EPA from 17/1/2013

To examine monitoring results for Lough Allen in response to local concern about increased pollution: EPA 7/2/2013

Foam in the Aquatic Environment. Schilling & Zessner. Vienna University of Technology (2011)

Images of the various types of Pollution discussed in this document can be seen HERE

The format used to report this process of discussion and areas of agreement or disagreement is based on selected passages from our submission on the Left and their resppnse either in writing or personal comment, shown on the Right. The centre column is used to clarify or explain differences or agreements


What we Submitted...

Discussion and Comment

The EPA response


 — All items are quoted from our Submission to the EPA —


— Grey items are comments; Black text are quotes from EPA document —


The rapid onset of pollution in Lough Allen has caught us all by surprise. We, because of our obsession with photographing and recording and counting rare species over the last five years or so, have become aware of it perhaps more than others. But that is not to say that many people living on the lake, and many fishermen, have not commented to us on many aspects of the change that we all see now. In the last year or two it has become a popular issue, but still, we are not aware of anyone taking any actions to curtail it.


“The main pressure affecting most lakes in Ireland is eutrophication. The WFD [EU Water Framework Directive] requires lakes to be classified into one of five classes: High, Good, Moderate, Poor or Bad... For nutrient conditions, given the conditions at most of the stations, the lake was classified as good for general chemical and physical parameters for the period 2009-2011.”


At present... the water quality in Lough Allen is not good. It frequently appears acceptable for short periods but any time we have gone out on a survey... we have always come across pockets of pollution that were not there four or five years ago.

Without knowing what the source is it is not possible to definitively say that it is not synthetic; we believe it is! Also there is both a Smokeless Coal plant and a Timber handling plant adjacent to the Lake.

“One of the concerns raised by local residents was of the presence of foam on the lake shore. However in the absence of a substantial STW or a tannery or paper mill discharging untreated waste directly into the lake then the foam is likely to be natural.”


Recently... we have surveyed 22 small streams and ditches entering all sections Lough Allen... from both a technical point of view, and from an observation point of view... There seems to be an ongoing process of low-level contamination of the lake from widely diverse sources.

We invited the EPA to replicate that survey! We do not support the policy of surveying large bodies of open water; there are too many variables. Also there will be no means of protecting the environment by way of determining the source of any pollutant found. Stream based testing was done by An Foras Forbartha in the past?

The EPA said that it wasn’t their policy do point testing in local streams but concentrated their effort on the boader picture. (EPA pers comm.)


From 2008 onwards, very slight traces of pollution began to be detectable in particular circumstances and in particular places. Typically we are talking about a very thin line of hardly any width, but extending over a considerable distance, lying on shores facing the oncoming wind. Typically these would be in reasonably calm days with just a slight breeze.

They provided us with a paper that indicates that foaming is a real possibility — coming from improperly handled domestic waste water..

The EPA did not accept that the foam was synthetic in origin but admitted that they had not studied foam much!  (EPA pers comm.)


In April 2011, a very major episode of deposition (by weather conditions) of pollutants on the north shore of the lake occurred following a period of sustained southerly winds coming straight up the lake. Banks of foam were piled about 15 cm. high and running back along the shore for up to 3 metres. These remained for a long period and left behind deposits which later became glaringly blue, probably indicating the presence of Cyanophyceae ('Blue-green algae')


“An examination of photographs of foam appeared relatively normal for a large exposed lake where foam will be generated by mechanical means given the big fetch. This will accumulate at the surface and blow shoreward.”

Did not appear to accept our links between foam banks and later blue-green deposits. (EPA pers comm.)


Synthetic foam is detectable by walking anywhere along the shores of Lough Allen and... by traversing the lake in a boat... The foam we are referring to is not natural foam. We do not believe it has a natural source... It is a new phenomenon and, outside of our own experience, most other people who use the lake are not aware of this level of pollution in their memory. It is growing rapidly and we cannot think of any plausible natural source for such contamination that would lead to this rate of increasing and persistent pollution.


“One of the studies reported by Schilling and Zessner (2011) found lots of diatoms in foam and the formation of foams can be derived from exudates of algae. Lough Allen has a good source of available silica in Spring and it is likely that the diatom population may be big enough to cause this. The could be verified by checking the foam for diatom frustules and the timing of foam occurrence — whether it reaches a maxima in Spring.”


The foam is very small-bubbled foam; it doesn't have the large bubbles of more natural foam like you get from bogs, or from cattle using the water. It is initially very white, though obviously it can become contaminated by insects or mud or sand. It does reappear after still weather! Natural foams, by and large, do not have this ability to foam, be reabsorbed, and then on re-agitation become foamy again. This is typical of things like washing up powders or liquids, and is a mark of modern day synthetic detergents containing surfactants.

EPA were under the impression that some of the outfall from Drumshanbo Sewage works exited via Acres Lake. We explained that this was nigh impossible given the permanent closure of the locks and the normal water gradient into rather that out of L. Allen. Waste will flow directly through their sample area and out via the Sluices. (Hence, we suggested, the anomaly!)

Drumshanbo works was our first suspected target for synthetic foam many years ago but now (2013) the source is much more dispersed.

“It is also clear that one of the stations [in the lake near Corlough] is influenced by anthropogenic inputs [synthetic?] and the discharges from Drumshanbo sewage treatment works are likely to play a role in this. However there may be other localised sources or diffuse pollution affecting this station as it is located in a reasonably isolated basin near Corlough, while the sewage treatment work from Drumshanbo discharges to a small river feeding into a separate small basin further south near Carricknabrack. The relative role of pressure from the STW will depend on the circulation patterns at this end of the lake towards the two outflows.”


The third type of contamination, we are seeing, would be derivatives of foam. Here we are talking about the most lethal type of pollution that we have seen in Lough Allen, i.e. blue-green algae (sic), that have been present for the last two years, and have led to the loss of dogs in 2012... Significantly, the death of dogs is due to their susceptibility to Cyanophyceae toxins. Of all animals, including humans, they are the most prone to being affected by the presence of blue-green algae.


Blue-green algal blooms occur in many lakes around Ireland. The organisms responsible are present in waters normally in small numbers. The water in Lough Allen was tested, in 2009, for phytoplankton. Colonies of Anaebaena [a Cyanophcyea] were not significant apart from an abnormally high level in one station which was not consistent and probably mistaken. (EPA pers comm.)


There have been cases in Lough Allen of rashes, appearing in young people entering the water and parents having to wash their children after they have been in the lake, or make them wear wet suits. This seems unacceptable in a wild environment like Lough Allen with a low population and copious rainfall.


Rashes in humans are often caused by high numbers of Dinoflagellates in the water as well as by Cyanophyceae. Dinoflagellates typically are present later in the Summer. (EPA pers comm.)


We think the foam is an indicator of eutrophication — enrichment by phosphate — and the phosphate in good warm weather is causing the algal blooms like we have seen last Summer. This is very serious, and needs to be controlled straight away.


The EPA officer did not really accept that the foam around the lake was an indicator of pollution but did think there was scope for studying this based on the Schilling and Zessner paper. (EPA pers comm.)


... we started to monitor the change, particularly in 2011... and we devised methods of recording the presence of synthetic foam. These included recording its extent, defining what we felt was synthetic foam, and doing very simple practical tests (to check the nature of this foam) such as re-foaming tests, persistence tests, etc. We also reported the rapidly increasing foaming levels in 2010 and 2011 to Leitrim County Council and through them, made contact with the EPA.


The EPA had not studied foam but had recently come across the above paper reviewing the occurrence and cause of foam across Europe and America (Schilling and Zessner). They accepted our idea of studying foam based on that research and determining likely sources and causes of foam. (EPA pers comm.)


In 2012... a couple of dogs died, clearly due to algal blooms, almost instantly on emerging from the water on a hot day. We were alerted about this when we returned but by this time the weather had changed and there was little visible signs of algal bloom where the dogs had died. But there were streaks present in the water for a lot of the Summer, gradually declining as the weather got colder and wetter.

We explained that both the owners and ourselves had tried hard to get a test but it proved impossible and we were given the impression that there was no specific test available?

The EPA spokesman accepted that the dogs had died from an algal bloom and said it would have been nice to get a conclusive Veterinarian test. (EPA pers comm.)


... if we get a long hot Summer, we face major problems of blue-green algal blooms in Lough Allen which will kill dogs, may damage livestock, and can affect the health and recreation of humans, and would definitely make Lough Allen a bit of a disaster zone for tourism.

We were surprised! What do they know? We have always assumed that given the enrichment of the lake, as shown by foam deposits on all shores, a level of nutrient would have built up that would make a bloom inevitable give some warm calm weather?

The EPA expressed an opinion that there would be no Blue-green algal bloom this Summer (2013), or that there was any particular new contamination threat. (EPA pers comm.)


... we would hope to liaise more closely with the EPA. They have been enormously helpful in providing us with their environmental data, their satellite data, their physical data and macrobiotic data. We feel we can play our part by being on the ground, making local observations and reporting or recording them either to the EPA, or directly on our website, as quickly as we can.


(No response.)


There have been no signs in the last few years that this problem is a temporary problem, a transient problem, or one that is going to be ameliorated. There are many signs that it is of human origin, that it is phosphate based, and that phosphate is most likely coming from detergents of one form or another.

Throughout our website and our reports we raise the question of Septic tanks as multiple point sources of phosphate and have provided evidence of a synthetic type foam now present in many small streams where it was not present a few years ago. The EPA ignore this factor, as they do for two fuel and timber processors on the Arigna and Shannon rivers.

“Current concentrations of TP [total phosphorus] and chlorophyll a are similar to historical data for the lake... A review by the GIS team in the EPA revealed only three STW in the catchment and no major industrial licensed discharges.”

They did say that the Drumshanbo treatment plant could cause some pollution in the southern part of L. Allen. (EPA pers comm.)



The technology available for measuring phosphate in water is not sensitive enough to measure critical levels of phosphate in open water. It may work in small streams where the water content is low and the phosphate content — perhaps from a nearby mechanised septic tank — is high.

Their measuring stations are all in open water except for the most southerly one near Drumshanbo. Not surprisingly that is the only one to register significant high levels taking their admission that this may be an anthropogenic source of pollutants.

The EPA measures Total Phosphorus in open water and are confident that their measuring techniques are sensitive enough to detect and monitor the very low level changes that will be present in such an open body of water. They do not measure P in streams or possible point sources. (EPA pers comm.)


The biggest indicator and proof of the contamination of Lough Allen is, to our mind, the blue-green algal blooms. These do not occur in oligotrophic waters; they occur in enriched waters! And phosphate, at levels of 0.1 ppm, is internationally regarded as being a trigger for the initiation of such algal blooms.

Seems we agree here... just they call it eutrophication and seem to accept that that is natural whereas we think it is due to an artificially increased level of phosphates and other chemicals entering the lake The EPA are simply measuring the change and reporting it!.

The EPA consider that Lough Allen is now mesotrophic whereas it used to be oligotrophic. This is based on TP and Chlorophyll a levels. (EPA pers comm.)


Here [in adapting monitoring techniques] we are talking about the need to design methods of measuring and monitoring increasing pollution in Lough Allen, to reflect the sudden and serious nature of what has happened in the last five or six years. It is not acceptable to see this as part of a global or national trend of increasing eutrophication... which is inevitable!

One of their results from the Station at Drumshanbo now reflects that at that point Lough Allen was indeed eutrophic instead of mesotrophic , which they do not make clear in their report!

The EPA believe that what is happening in Lough Allen simply reflects a  National tendency to increasing eutrophication in all lakes. (EPA pers comm.)


We see a major role, in collaboration with national authorities, for the latter category — people on the ground being aware of what is natural and what is unnatural, what is new and what is unchanged? Most people around Lough Allen are already well aware that there are major changes occurring in the water quality in the last few years.


They appreciate the anger and commitment of local people and  say it is good to see communities engaged in protecting their own places. (EPA pers comm.)


Are there methods of recording the length of shoreline that has a continuous deposition of foam, or can blobs of foam floating on the open water be measured in terms of percentage coverage of the water, and do these two observations have any technical validity?

Yes, we are engaged in that process...

Can it be quantified and standardised? (EPA pers comm.)


The main reason why we regard foam in Lough Allen as pollution rather than natural foaming, is that it suddenly appeared, and since it appeared in 2007/2008 it has become steadily more prevalent. The second reason for defining this foam as pollution is the nature of the foam, the way it disappears and re-appears. It is very fine-textured, very white, has the ability to persist for a long time, and after it is 're-absorbed' into the water, it can re-appear when the water is agitated. This is very much the property of synthetic detergents.

It was very hard to get the spokesman to talk about other indicators clearly demonstrating change in the water quality over a short period. Nor to recognise the body of work we had submitted examining the quality of that foam or the tests we were developing — even though those were quite coincident with modern research. There is an element of condoning a decline in our environment in this ‘see-no-evil’ approach?

Referred to other measurements showing that the water was of ‘good’ quality in chemical and physical terms. Made no comment on concerns about the new and persistent nature of the foam that we had raised. (EPA pers comm.)


Even with sensitive equipment it is difficult to measure the level of phosphate that is sufficient to trigger an algal bloom. [Low level phosphate monitors are]  probably best used in streams and ditches to identify local sources of higher levels of phosphate entering the lake.

Don’t agree! We think a cost-effective instrument applied thoughtfully in likely areas of high concentration is more meaningful than the height of technology applied randomly regardless of location or weather.

Did not have much regard for phosphate meters but not sure if this referred to high level or low level devices. Insisted that their measurement of TP in open water twice a year was feasible and accurate even if Phosphorous was only present in trace amounts. (EPA pers comm.)


Technical chemical and physical methods are limited by the fact that Cyanophyceae respond rapidly to very low levels of enrichment which are almost beyond the technical levels of monitoring. The 'technology' most appropriate seems to be observation of changes in the levels of plants and bacteria, growing in the water or onshore. In particular green algae, and the dangerous one, blue-green algae, both of which will respond to enrichment.


No Comment.


It is clear, therefore, that any observation of change, be it a new type of foam, be it persistent foam on the shore, be it blue-green patches, be it scum on the lake which seems to be persistent and unnatural, or the dispersed bands of Cyanophyceae along the middle of the lake following the flow of water — is all very relevant to understanding and managing the pollution of Lough Allen. All of these observations are important indicators of dangerous levels of phosphate pollution prior to an algal bloom.


Accepted that local knowledge and local observations are useful. (EPA pers comm.)


So it is useful to measure the extent of foam and perhaps a function of could be to provide a simple picture card showing examples of foam and a rating system for these. This could relate to foam, to blooming streaks, to patterns of spots or continuous 'soup' on the lake. And all these various forms of pollution could be given weighting and value. Then we could have a system of records, from several people around the lake, of the time and extent of the presence of foam or more serious forms of pollution in Lough Allen.

This has been done. A sample Test Card for Visual Signs is available HERE.

The EPA suggested that this is something that local people could usefully undertake and that more widely based and standardised qualitiative observations could be meaningful.  (EPA pers comm.)


We would very much welcome more routine assessment of Lough Allen but appreciate that the EPA has the whole country to cover and not the staff to do it. But they do respond, and have helped us in the past, and analysed bloom samples. This, we trust, will continue and the liaison could be improved though a pointed and planned campaign of voluntary/professional partnership.


Spokesman said they were always available to help with testing samples specifically in identifying organisms within blue-green algal blooms and for the presence of toxins in the water. (EPA pers comm.)


Without doing that [returning Lough Allen back to the condition it was in 2006] there is no possibility of promoting the area as an area for photo-tourism, wildlife tourism, swimming, recreation, and other shoreline activities. The loss of that type of visitor would be a major set-back for the local region, as this area, and the mountains and the rivers, has enormous potential if it was as pristine as formerly.


No Comment


The other species that has shown population change is the Daubenton's Bat, which has shown a marked decline in records in 2012... This may also be mainly due to weather but there is one significant fact; the survey site on the Shannon River just below the sluices leaving Lough Allen, on both occasions in 2012, had large amounts, or blobs, of persistent foam coming through the Sluices and floating down the river. There is evidence that Daubenton's Bats echolocation and feeding techniques are affected by rapids or disturbances in the water. Possibly the effect of foam on the surface of the water could upset their feeding. And if their feeding effectiveness is reduced, they may either abandon breeding or not breed successfully.

We only made a quick reference to this as it was outside the area of the EPA’s work. It is simply an interesting biological conundrum which we will follow up this year.

Not their expertise.


... there does seem to be a very clear causal link between the start and the progress of the increase in pollution, with the timing of the changeover to the new style mechanised septic tanks. There may be a couple of years' delay in the approval of such equipment and the arrival of the foam, but this would obviously relate to the installation of the septic tanks, the building of the houses, the occupation of the houses and the start of the release from these systems of untreated phosphates.

We informed the EPA of the conditions being imposed by Planning Authority in Leitrim in the recent past and the consequent visibility of foam — analogous to the foam seen in Lough Allen — in ditches beside modern houses. They seemed surprised with this information!

The  EPA spokesman was not aware of the technical details of new mechanised Septic Tanks and the new regulation placing them adjacent to, and draining into, ditches and streams. (EPA pers comm.)


We would be highly critical of the decision to allow such septic tanks to be installed very close to drains and ditches and to be allowed to drain into these after treatment because the material coming out of the septic tank is treated mainly for sewage but does not have any treatment for household detergent, shampoos, washing up liquids, or the countless other domestic cleaning products now coming on the market. It is a regular sight to see foam deposits coming out of an innocent party's house and flowing into the local stream or local lake.


No Comment.


Other possible causes would be Municipal treatment works, but the only one we are familiar with, in Drumshanbo, does not seem to have any particularly high levels of phosphates associated with it? We are surprised, because it does seem to be a fairly basic treatment plant. However, there is plenty of available space in that area, which we have discussed with the local Tidy Towns group, to put in a very attractive reed bed (or other biological treatment) just below the treatment plant.

We may have taken our eye off the ball here as we do get significant foaming here in the right weather. But this is a sheltered area and with limitied richness in biodiversity and not a priority study area. We have lobbied with a local voluntary group to have a biological treatment pond installed here. Maybe this sholud be a priority?

EPA tests show that there are  significant raised TP levels of a man-made origin being detected near to the exit from these works. They also stated that there are other technical means to reduce Phosphorus emissions from such plants. (EPA pers comm.)


Bearing in mind the many observations over many years, the synchronicity between planning changes and the widespread appearance of the 'new foam', the increasing levels of foam, and the eutrophication of Lough Allen, makes us conclude that it is most likely that the installation of septic tanks, that do not treat phosphate, and are permitted very close to waterways, is the singular main cause of the deteriorating water in Lough Allen.

When we compare foaming visible from modern septic tanks, foam appearing in small streams that never had it, and the sort of foam you get on driveways when washing a car, we cannot but think that these are the clues to what has happened in Lough Allen over the past five or six years!

Merely a general comment that they hoped that the new Septic Tank registration process might improve the water quality in Lough Allen. (EPA pers comm.)


Every river, stream or farm ditch entering Lough Allen needs to be carefully monitored for the possibility of it carrying waste material into Lough Allen. Such specific waste (as we have specified above) would, typically, be coming from septic tanks but could possibly derive from forestry or other commercial activities, dredging activities on rivers where bog flows have necessitated such works, and other construction work.

Hopefully domestic (and other) wastewater can be better controlled and none of it be allowed to escape untreated into the natural environment. Many more highly populated places do manage to retain clean public water resources. We would be happy to keep an eye on foam levels entering the lake and record any fall off in levels seen.

No commitment to this work from the EPA. They are quite happy with their periodic open water tests. (EPA pers comm.)


The registration of septic tanks definitely has the potential to benefit in this clean up, but it should not be seen as a punitive action against citizens. If there is blame in regard to septic tanks, obviously it could be due to the owners, but primarily and specifically, it seems to be due to new conditions imposed on owners. The blame here lies on the National and Local Authorities.

Full cost grants where faulty designs were imposed, we wondered?

The registration and inspection of Septic Tanks that is coming online may improve this situation and they understood that grants would be available for remediation. (EPA pers comm.)


But no septic tank, or treatment system, should be allowed to operate, directly discharging water from the mechanised unit into a stream or ditch nearby. To be slightly critical, we do have the impression that people in manufacturing and technical design feel that these are 'wonder machines' and do not accept that they simply aerate and agitate the water with the purpose of promoting bacterial action to remove nitrates and nitrites. This merely serves to create a detectable foam with any detergent products that are in the system. Similarly the concept of mixing 'grey water' (domestic waste water that does not contain sewage) with the sewage, does not seem a good idea to us?

Social ecological principles should be applied just as much as conventional engineering considerations to planning for living in the countryside. The rules are simple and well known but can be overlooked. In fact some changes may have overthrown tried and tested methods that may indeed have worked better!

(No Comment.)