Read An Taisce's submission on the draft Clean Air Strategy for Ireland here.

What is the Clean Air Strategy, and why does it matter? 

A Clean Air Strategy should do what it says on the tin - ensure that we all have the right to breathe clean, unpolluted air, no matter where we live in the country. The Government’s current Draft Clean Air Strategy is not ambitious or robust enough to create the change needed.

Achieving Clean Air in Ireland would have enormous benefits for society. In 2019, air pollution was linked to over 1,300 avoidable premature deaths in Ireland. (1)

The main sources of air pollution are also Ireland’s main sources of carbon emissions: transport, home heating and intensive agriculture. 

The Government’s Plan is currently at draft stage, and it is open to public consultation until Tuesday, 3 May. If you care about clean air make your own submission by writing an email to: [email protected] with the subject line: Clean Air Strategy Public Consultation, before Tuesday, 3 May. Read our recommendations below and include any you feel are a priority. 

An Taisce’s Key Recommendations are:

Legislate for WHO Air Quality limits by 2025

The WHO Air Quality Guidelines are a set of evidence-based recommended limits for specific air pollutants developed to help countries achieve air quality that protects our public health.

Create Low Emission Zones in our cities 

A Low Emission Zone is an area of a city in where access for heavily polluting vehicles is restricted. Only low or zero-emission vehicles are given access, and highly polluting vehicles may be required to pay congestion charges.

Start an Active Travel Revolution

We need more investment for safe cycling and walking infrastructure. Cycling and walking should be the priority in towns and cities, for better air quality, lowering carbon emissions and our physical and mental health. We need to make sure cycling is accessible to as many people as possible through more subsidised bike schemes and affordable rental schemes. 

Subsidise and Improve Public Transport

We need to make public transport a better alternative to the private car through subsidising and improving the network.

Invest in Alternatives to Air Travel

The Government is ploughing ahead with its plan to build another runway in Dublin Airport, and increase its flight numbers dramatically. This would have serious consequences for air pollution and for carbon emissions. The North Runway project should be cancelled by the Government. Investment should go to integrated infrastructure like ferries and trains instead.

Support Farmers to Reduce Ammonia Emissions

Subsidy and grant schemes should be introduced that facilitate farmers to reduce the intensity of their ammonia emissions, and to diversify their farms.

Expedite Retrofitting for Most Impacted by Solid Fuel Regulation

The elimination of solid fuel burning in Ireland is a crucial target, but it must be achieved by providing realistic and timely alternatives not by depriving people on low incomes of access to home heating. This impacted most should be prioritised in the National Retrofitting Scheme and any backlogs addressed. 

(1) EPA, Air Quality in Ireland 2019 

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Further Explanation

What value does my input have in this process? 

The Government’s Plan is currently at draft stage, and it is open to public consultation until Tuesday, 3 May. The Plan falls far short of its potential, and misses the opportunity to fundamentally transform our emissions. Simply put, the Government needs to be told that the people expect better, more far-reaching solutions, backed up by legislation and with specific timelines for action. If enough people make their voices heard, the Government will be left with no choice but to redraft the Strategy, and give us the Clean Air roadmap we all deserve. 

In the next section, we’ve laid out more detail on our recommendations for Clean Air, to help you with your submission.

Make your own submission by writing an email to: [email protected] with the subject line: Clean Air Strategy Public Consultation, before Tuesday, 3 May. 

What would a good Clean Air Strategy look like? 

The Strategy should lay out a road map for achieving major reductions in air pollution from the main sources of pollution. They are: Transport, Home Heating, and Intensive Agriculture. In general, the Strategy should: 

Recognise the Right to Breathe Clean Air

The Clean Air Strategy should explicitly recognise that every person in the country has a right to breathe clean air. 

Legislate for World Health Organisation standards

Ireland’s air pollution levels are dramatically higher than the safe levels that the WHO has identified. The government should commit to introducing legislation setting out a legislative path to getting Ireland to WHO standards by 2025 at the latest. The legislation should be completed this year. 

Be more specific! 

The Draft Strategy includes some very ambitious rhetoric, but it is light on detail. The Strategy should be revised to specify how the priority areas, and the overall objective of the Strategy, are to be implemented and delivered in a timely manner. This should include specific timelines, detailed targets, and clear implementation plans for each major sectoral area.

 

Transport

• Legislate for Low Emission Zones in our cities 

Low Emission Zones are crucial in reducing the air pollution impact of transport. Our city-centres should be designated as Low Emission Zones. This means that heavily polluting vehicles would be restricted from access to the Zone, and congestion charges would be applied. They have been successfully implemented in many European cities, including Paris, Amsterdam, Brussels, London and more. In London, air pollution reduced by 44% in 3 years, largely due to the use of Low Emission Zones. 

• Active Travel Revolution

We should be moving much faster to encourage people to use active travel instead of private cars. This involves acceleration of cycling infrastructure projects, pedestrianisation of roads, and the introduction of grant schemes for electric bikes and scooters to make them more accessible for as many people as possible. Speed limits 30kph default all built up areas. 

• Invest in Alternatives to Air Travel

We are in a climate crisis. Despite this, the Government is ploughing ahead with its plan to build another runway in Dublin Airport, and increase its flight numbers dramatically. This would have serious consequences for air pollution and for carbon emissions. The North Runway project should be cancelled by the Government and investment should be put into alternative modes of transport and integrated infrastructure like ferries and trains.

Agriculture 

• Reduce Ammonia Emissions

Agriculture is the main source of ammonia emissions in Ireland. Ammonia is very dangerous for human health, and a major problem for climate. Ireland is far above the legal limits for ammonia pollution, and has been the subject of complaints by the European Commission. According to the EPA, the cause of our spiralling ammonia emissions is primarily the increase in cattle numbers. 

• Fund the Just Transition for Farmers

Principles of Just Transition should be at the heart of reforms for agriculture, supported by appropriate funding. A fund should be created to support farming communities in their transition from intensive agricultural output to more sustainable modes of production and activity. Crucially, our national agricultural policy means that most farmers have little choice but to increase the intensity of their output. The Government needs to address this, and incentivise farmers to reduce intensity and increase diversity on their lands. 

• Learn from Other Countries

In 2020, the United Kingdom published its air quality plan, which includes plans to cut ammonia emissions from agriculture by 16% by 2030. At the end of 2021, the Dutch government published a €25 billion plan to reduce livestock numbers by up to 33%, including compensation schemes for farmers, and supporting the transition from intensive to extensive farming methods. This scale of ambition is absent in Ireland. 

Home Heating

• Coherent Plan for Transitioning Away from Solid Fuels

In 2021, the Government announced its new Solid Fuel Regulations. The Regulation of solid fuel is very important - 55% of particulate matter pollution in Ireland comes from houses burning solid fuel. However, there is a lot of confusion around the plan to phase out reliance on turf burning in Ireland.

The government should develop a coherent plan for the rapid transition away from turf burning, with a specialised and expedited strea, of the retrofit scheme designed to help those reliant on turf to move away from its use as quickly as possible. People cannot be left without access to fuel in the winter, and it is incumbent on the Government to ensure that that does not happen while also protecting our peatlands. 

• “Natural” Gas is Not the Answer

There has been a rapid increase in reliance on natural gas in Ireland in recent years, instigated by Government policy. Gas is a fossil fuel, and its primary component is Methane. Methane has a global warming potential 21 times higher than carbon dioxide over a 100-year period, and methane leaks from extraction and transportation of natural gas are a significant problem. Continued reliance on natural gas in Government policy is a recipe for climate catastrophe. Instead, the Clean Air strategy should reaffirm a strategy for renewable energy production in Ireland. 

 

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