In our submission to the Department of Environment, Climate Action and Communications on the National Air Pollution Control Programme (NAPCP), An Taisce has called for the multiple actions required on smoky peat, coal and wood burning, air particle polluting vehicles and animal agriculture ammonia to be advanced as a public health and legal imperative.

A summary of our main points and recommendations:

Human Health Impact

The risk posed to human health should not be underestimated. The Department of Communications, Climate Action and Environment’s own data asserts that air pollution in Ireland causes a loss in life expectancy of 394 years per 100,000 inhabitants. Across the country, the Department estimated that, for example, a total of 18,200 years of life were lost to air pollution in 2013.[i] According to a study carried out in Denmark, ammonia exposure to children increases the incidence of asthma development.[ii] Ireland is already peculiarly vulnerable to respiratory illnesses, including asthma – Ireland is ninth in the world for prevalence of asthma in children.[iii]

Air pollution related to fine particulate matter (PM2.5) alone is linked to some 1,300 premature deaths in Ireland in 2019[iv] – up from 1,180 in 2018 – and almost nine times the death toll on the Republic’s roads.

Solid Fuel Burning

The main threat to air quality comes in the form of minute particles PM2.5. These arise mainly from solid fuel burning, according to the Environmental Protection Agency (EPA).[v] Air quality in Dublin, and a range of rural towns including Ennis, Tralee, Cork city, Macroom, Letterkenny and Enniscorthy, has been consistently found to significantly breach World Health Organisation levels for PM2.5 particles.[vi]

Traffic Pollution

To place the importance and urgency of meaningful action to address Nitrogen Oxides (NOx) emissions in context, the EPA’s air quality monitoring identified an exceedance of legal limit values of NOx in 2019 at a monitoring station in St John’s Road West, in Dublin. As a result, the Urban-Transport Related Air Pollution Working Group was convened, as noted in the draft report. There has been no quantifiable progress made by the group to date, and although the draft update to the NAPCP stated that an interim report would be published by UTRAP before the end of 2020, at the time of writing no such report has been made available. This is despite the fact that all four of Dublin’s Councils are legally obliged to take action ‘as soon as possible’ to address any legal exceedance within the city.[vii]

Although there has only been one formally recorded incidence of exceedance of the legal limit values for NOx, modelling undertaken by the EPA in 2019 indicates that the true scale of the problem is in fact much more serious. According to the modelling data published by the EPA, they estimate that 11 separate monitoring locations are in exceedance, and a great many of Dublin’s most congested streets are above the 40ug/m3 annual average limit.[viii]

Agricultural Ammonia Air Pollution

The intensification of animal agriculture though the Department of Agriculture, industry and Bord Bia promoted Foodwise 2025 strategy adopted in 2015 has pushed Ireland in excess of the EU ammonia emission ceiling directive since 2015. Ammonia has multiple adverse impacts both on human health, nature and biodiversity.[ix]

Legal Obligations

The meeting of EU emission limit  obligations is an immediate obligation, which if not met exposes the State  and sectors involved to legal actions. This is already happening in other countries, particularly from individuals or communities directly affected by adverse health impacts.[x]

The 2016 ammonia threshold breach and failure to mitigate the adverse impact of the Foodwise 2025 animal agriculture intensification strategy is already the subject of EU infringement complaint by An Taisce made in July 2020. In a preliminary response in January 2021 the Commission has stated that it shared the concern raised by An Taisce. (further details of this complaint are available in the attached briefing document.)

A further significant issue arises from the transboundary impact on Irish border counties from the high level of intensive animal agriculture in Northern Ireland. (see attached letter to Department of Agriculture, Environment, and Rural Affairs).

Actions to Achieve Multiple Co-Benefits

Policy measures and actions should not be limited to bare compliance with EU legal minimum obligations. The more stringent, health-based guidelines provided by the World Health Organisation (WHO) are in fact the metric against which public policy should be measured. The WHO’s clean air standards place evidence-based public health and well-being at their heart, and this should be the bedrock foundation of all public policy in this arena.

Effective clean air policy also has multiple important co-benefits for nature and climate action. The improvement of ambient air quality requires a rapid transition to the following policy objectives, all of which are important aspects of climate action as well:

• Efficient home heating from renewable sources
• A major shift from the dominance of private car use, towards cycling, walking and mass transit;
• A more plant based diet, facilitating a transition in the agricultural sector toward less pollutant and more sustainable activities.

Read our full submission here.

Notes

[i] Department of Communications, Climate Action and Environment, Cleaning our Air: Public Consultation to inform the development of a Clean Air Strategy (2017) p. 8

[ii] Holste, Gitte et al, Ammonia, Ammonium, and the risk of asthma: A register-based case-control study in Danish children (Environmental Epidemiology, 2018)

[iii] Global Initiative for Asthma, Global Strategy for Asthma Management and Prevention (2016) available at:

https://ginasthma.org/ wp-content/uploads/2016/04/GINA-Appendix-2016- final.pdf (accessed January 2021).

[iv] EPA, Air Quality in Ireland 2019 (p2)

[v] EPA, Air Quality in Ireland 2019 (p22)

[vi] The WHO’s quality guideline values for PM2.5 are 10μg/m3 annual mean, and 25 μg/m3 24-hour mean.

[vii] Clean Air for Europe Directive,

[viii] EPA, Urban Environmental Indicators (2019)

[ix] EPA Research, Assessment of the Impact of Ammonia Emissions from Intensive Agriculture (2020)

[x] Transport & Environment, Six EU Governments Finally face legal action over air pollution (2018) available at: https://www.transportenvironment.org/news/six-eu-governments-finally-face-legal-action-over-air-pollution