“…Spain and Ireland stand out. Both countries are equally bad in terms of exceeding their Kyoto targets, but Ireland’s per capita CO2 emissions are double those of Spain.”

A 2004 report by the European Environment Agency (EEA) was more emphatic:

-     For energy supply, Ireland was bottom of the EU table

-     In terms of using renewable energy, Ireland was fifth from the bottom

- For taking measures to capture heat generated by power plants, Ireland   came second from the bottom

- When it came to action to reduce emissions from agriculture, Ireland was bottom of the table – the only member state expected not to cut them

- But when it came to transport, Ireland’s failure was off the scale; without corrective action, its emissions were set to leap 180%, in the 20 years from 1990 to 2010 – a rate of increase more than twice that of Spain, which is the second worst offender (with a projected 75% increase).

(Source: Chaos at the Crossroads, Frank McDonald and James Nix, published by Gandon Books, 2005)

Ireland may be aptly described as the European Cockpit for confronting Climate Change and Sustainability.  As an island, with its major urban centres located on the coast or tidal rivers, it is particularly exposed to any rise in sea levels.  It might be expected therefore, that the Irish Government would be at the centre of global and European concern to confront Climate Change. 

The opposite is the case.  Ireland is currently experiencing some of the most rapid development, and in particular, low density urban sprawl in Europe.  In considering sustainability indicators, Irish factors such as per capita Greenhouse gas generation and road and air transport mileage, and level of increase in transport emissions are the highest in Europe.  The country is experiencing

• Massive inward investment from US companies in IT, pharmaceuticals and biotech, availing of low tax rates.

• Massive inward migration resulting in some of the highest population growth in Europe.

• A construction boom which, by international standards, is remarkable when the ratio of activity such as the hundreds of kilometres of motorways under construction or planned, or 80000 housing units under construction per annum, is evaluated on a population ratio basis. 

• The most fossil fuel-dependent country in Europe (Excluding Malta).

• Increase in peak power demand from under 3000MW in 1995 to 5000MW.

• The highest per capita waste generation in the EU at 869kg per person.

Kyoto Compliance - Policy & Reality

Ireland negotiated a 13% level increase on 1990 levels under Kyoto.  Already, levels are more than twice this amount in excess of Kyoto limits at over 26%. While the Government, through the Department of the Environment, Heritage & Local Government, published ‘A National Climate Change Strategy, Ireland’ in 2000, the range of measures outlined in this strategy have not been implemented.  While there has been a reduction in Greenhouse gas generation through the closure of major fertilizer plants, this simply means that the environmental impact of fertilizer production in Ireland is now generated in India, its major fertilizer supply source, as there is now no indigenous fertilizer production.

Transport Emissions – The Fastest Growing Contributor

Transport emissions are the fastest growing category of Greenhouse gases in Ireland.  The European Environmental Agency bar chart measuring person/kilometre transport demand for road, rail and air shows that Ireland is overall highest in Europe and individually highest for road vehicle and rail.  Another instructive graph is the ratio of increased transport emissions in the EU, which shows Ireland at the top of the bar chart at almost 130%, the biggest increase for any sector, with road transport accounting for 93% of the total volume of 11.5 million tonnes of carbon dioxide emissions from transport. 
While policies are set out in ‘National Climate Change Strategy for Ireland, 2000’ to address transport generated Greenhouse gases through a combination of taxation, fuel efficiency and demand management measures, no such policies have actually been put in place.

Indeed, current Irish Government policies endorsed by local authorities exercising their subsidiary function as planning authorities, directly contradict the provisions ‘The National Climate Change Strategy’ in focussing on an inter-regional road-based motorway and dual carriageway programme.  While Ireland had a fine rail system until the 1950’s, much of it, including key strategic regional connections, were phased out during the 1960’s.  Outside of the Dublin commuter rail lines and the rail links between Dublin and the main urban centres, there is no rail travel of any significant level. 

The majority of the 80000 new housing units being built annually are located in non-public transport accessible locations on the fringes of the larger urban centres, or on the fringes of smaller towns and villages within the car-based commuter catchments of larger urban centres and most significantly, a full 20% of the total annual housing stock completions are ‘one-offs’ constructed on road fronted sites outside the speed limits of towns and villages, scattered in long distances across the countryside, either individually or in ribbon development strips and rarely with any planning or nucleation.
 
The most recent available transport figures under a range of headings relating to Ireland are summarised in an Irish Times Article of 18th July 2006:
 
• Average car driven 16,892 km per year

• Number of people driving to work jumped 16 points to 55% between 1991 and 2002

• Average length of commuting journey increased  from 11 km in 1996 to 16km in 2002

• Number of cars increased by two thirds from 939,022 to 1,582,833 between 1994 and 2004

• Number of HGVs and commercial vehicles nearly doubling from  135,809 to 268,082 between 1994 and 2004

• Decline of market share of rail freight from 5% in the 1980s to less then 1% today

• SUVs accounting for  8 % of new car sales in Ireland

• Transport accounting for 40% of Irelands CO2 emissions, increasing at 10% per year.

More difficult to quantify is the wider impact of car based urban sprawl which ranges from car based housing on urban fringes, dormitory commuter development in towns and villages for people employed in and around larger urban centres and one off housing.  While the NRA may argue that this is a land use and planning issue outside its remit, urban sprawl directly affects the operational capacity and travel time targets for inter urban journeys on national roads and potentially undermines the safety benefit on which the NRA is justifying the current road programme, by making feeder roads in urban sprawl catchment areas more dangerous.
 
There is no evidence of strategy or plan by the NRA to address the effect of these trends on National Road time targets, travel time targets, overall National Road safety targets and National land use and environmental policy.

Failure to meet vehicle fuel efficiency targets and demand management

Both the National Climate Change Ireland (NCCI) and the National Development Plan (NDP), EU funded inter regional road programmes are predicated on achieving reduction in Road Transport Greenhouse by fuel efficiency and demand management.
However, the opposite has occurred. The following are several extracts from an article published in The Irish Times of September 29, 2006 (see Appendix for full article):
“The study ‘Energy in Transport: Trends and Influencing Factors 2006’, produced by Fergal O’Leary, Martin Howley and Dr. Brian Ó Gallachόir of Sustainable Energy Ireland (SEI), found that fuel consumption for new petrol cars on the road in 2005 was 7.2 litres per 100km (40mpg), an increase of 1.6 per cent on average consumption in 2000. This indicates that newly purchased petrol cars are becoming less fuel efficient, the report said.”
“The study also found that the numbers of cars with engine sizes of 1.2 litres or less are declining, while larger engines have become more popular. The number with engine sizes above 1.9 litres has almost doubled since 1990.”
“The report, based partly on figures taken for the first time from NCT (National Car Testing) centres around the country, found that average car mileage had fallen between 2001 and 2005 by almost 10 per cent. Mr. Howley attributed this to an increase in the numbers of cars on the road, with many households owning two cars. In 2005 there were 507 cars for every 1000 adults in the State, up from 312 in 1990.”
“The report also found a 264 per cent increase in fuel consumption by road freight between 1990 and 2005, attributed in part to the high number of construction and road building trucks on the roads.”

Power Generation

Irish peak generation demand has risen from under 3000MW in 1993 to nearly 5000MW.
The National Climate Change Strategy 2000 provided for the closure of the 900MW coal burning Moneypoint Power Station on the Shannon Estuary by 2008, producing five million tonnes of CO2.
However, Government concern at the level of natural gas dependence for power generation resulted in an alternative proposal to recondition the plant for continued coal burning, substantially reducing NOX emissions with scrubbers, but marginally increasing CO2 emissions. Ireland is now among the most natural gas dependent countries in Europe to date with contribution from wind energy remaining marginal.
 

Energy

Ireland faces enormous energy challenges because of its low level indigenous energy production through inefficient peat extraction and sporadic and to date, non strategic wind energy development, which is achieving only 300MW at peak capacity,
with no more than one third of the main CO2-generating coal burning power station at Moneypoint.  Lobbying by the building construction and particularly by the cement and concrete industry has resulted in long-fingering of the EU Energy Performance of Buildings Directive 2002/91/EC and the loss of major opportunity to implement progressive energy conservation standards.

International Image Projected by Irish Government

The two main images being promoted by the Irish Government of the country internationally are of an economic miracle, attracting enormous inward investment and immigration, while at the same time remaining a clean, green island.  This does not address the reality of Irish Greenhouse gas emissions or the poor standard of waste management and protection of a European level endangered species such as the freshwater Pearl mussel.

Attitude of Government to Environmental NGOs in Ireland

The attitude of the Irish Government, notably the Taoiseach and the current and previous Environment Ministers, is significantly negative to the environmental NGO sector. When an environmental NGO raises a serious matter like breach of an EU directive affecting a State infrastructure project, they are attacked for impeding economic growth and development, and caring only “about swans and snails”.  Membership of environmental organisations is very low in Ireland, at a level of less than ten percent on a population ratio of membership in the UK and Northern European countries.

Statutory Consultee Role of An Taisce – The National Trust for Ireland

An Taisce is in the unenviable position of being the only environmental NGO to have statutory consultee status in Ireland, in comparison to the multiplicity of organisations which would share such responsibility in many other European countries.  All major developments, including road and motorway projects, airports, infrastructural and other projects under the EIA Directive, are referred to An Taisce as well as general applications for planning and development, aquaculture and forestry in landscape, ecological or heritage sensitive areas.  For this, An Taisce receives no financial support.  Instead, the organisation has suffered serious abuse in the media, including from Government Ministers and local Councillors, simply for making submissions and raising concerns about Climate Change, Urban Sprawl, Habitat Destruction, Breach of EU Directives and bad planning. 

Achievements of An Taisce’s planning and infrastructural consultee intervention since 2005

Under Irish Planning law, An Taisce is the only non-governmental body given a formal consultation role to monitor planning applications for a range of categories of development applications to local authorities. It has the entitlement to appeal at a reduced fee, local authority decisions, to a national planning appeals board, An Bord Pleanala. 

This function has been actively used with appeals resulting in the overturn of local authority decisions for a large number of major developments across the country, as well as for smaller developments in particular categories, e.g. commuter sprawl housing.

One of the most significant was the refusal of two applications, the second arising from a reapplication after refusal for the first of a 6000 seater Convention Centre at Citywest, County Dublin, where the prime ground of refusal was that the location was ‘remote from public transport.’

Infrastructural Development

During the lifetime of the current National Development Plan, 2000-2006, over 500km of motorways/dual carriageways have been approved between Dublin and the main urban centres, with the next Plan under preparation providing for the completion and construction of these roads and a further ‘Atlantic corridor’ running across the south and up the west of the country, linking the main regional centres. 

An Taisce has actively participated in 12 of the public Oral Hearings on these schemes, focussing in particular on the impact of generating increased use and emissions, including Climate Change–generating emissions, and generating unsustainable Land Use patters of urban sprawl.

An Taisce has played a major advocacy role in planning new interchange proposals at Cork Lough in Dublin/Fingal and on the Armagh Road outside Dundalk on the M1 Dublin-Belfast motorway, on the basis that these would accommodate car-based sprawl.

An Taisce was also successful in securing the nullification of a local authority road scheme in Athy, Co. Kildare, on the ground that it did not have the Environmental Impact Statement required under EU law and played a major part in securing the rejection of the scheme by An Bord Pleanala when a revised application was subject to EIA.  

Airport Expansion

Ireland set the European lead in ‘low cost’ airlines through Ryanair, whose management and fare policies were quickly followed by the State company, Aer Lingus, whose former Chief Executive, Willy Walsh, is now running BA and is a lead advocate in lobbying for the unfettered development of global aviation and the disregard of Climate Change.  Dublin Airport is one of the most rapidly expanding in Europe, with passenger demand having risen from 5.8 million in 1990 to 18 million in 2005.  An Taisce is playing an active part in a range of current application and consent schemes for a new northern runway, new terminal building and car parking to double the capacity of the airport, with the projected figure of some 38 million passengers per annum by 2025.

Strategy for Future Climate Change Advocacy and Planning and Infrastructural Development

An Taisce is seeking to develop its under-funded and under-resourced role as a Statutory Consultee for significant planning applications and infrastructural projects, with the aim of

• Taking a lead role in highlighting adverse Climate Change impacts through combined formal representation to consultation documents, submission periods and public Oral Hearings.
• Generation of Media Coverage and Public Awareness.
• Generation of legal complaints on EIA Directive breaches to the European Commission.

In particular, An Taisce is seeking to use more effectively, its statutory consultee role and the enormous information insight which this gives into the state and impact of planning and development, including energy, land use, transport and Greenhouse gas generation patterns.

Use of Legal Provisions of EIA Directive to Achieve Climate Change Mitigation

All major housing, transport, infrastructural and power-generating projects are subject to the EIA Directive.  The key principles of the Directive are the assembly of adequate information to allow all of the direct and indirect impacts of the projects to be properly assessed and adverse impacts to be properly mitigated.  To date, professional consultants and consent authorities in Ireland have not taken these provisions seriously and are accepting arguments for major car-based development, or airport development expansion, on the basis that Kyoto targets would somehow be met at an undefined later stage through fuel efficiency or better emission controlling road vehicles or planes.

The fact is that the professional consultants making these claims cannot substantiate them and the administrative and legal mechanisms provided in Ireland for making submissions on Environmental Impact Statements and the Oral Hearings, which occur for the larger projects, present a major arena to confront Climate Change denial and expose the blindness to reality so well summed up in the dictum by Upton Sinclair which was prominently cited in Al Gore’s An Inconvenient Truth.

Timing and Opportunity

There is an appropriateness of timing and an opportunity to achieve real change and impact which was not possible even a short time ago.  The scientific consensus on mounting Climate Change impact and increased media coverage now presents the opportunity for Climate Change issues to be considered seriously in the consideration of development proposals and infrastructural projects in Ireland.

An Taisce is seeking significant financial support to put in place the personnel to actively participate in the planning consultation process, take a lead role at Public Hearings in making Climate Change the lead issue, generate the support of public opinion and media coverage and ultimately, influence legal and political decision-makers.