Submission on Dublin City Council's Climate Action Plan

Children Protesting for Climate Action outside Leinster House
Children Protesting for Climate Action outside Leinster House

Dublin City Council recently sought feedback on their Climate Action Plan. Below is Senator Higgins's submission to the public consultation process.

General Comments 

I welcome Dublin City Council’s development of a Climate Change Action Plan and, as a public representative and a resident of Dublin, I appreciate the opportunity to contribute a few thoughts in relation to its development and implementation.

The public demand for greater climate action is strong and clear and cities have a pivotal role to play in tackling the causes and impacts of climate change and in shaping more sustainable ways for our communities to live together. It is great to see Dublin embrace the opportunity to demonstrate leadership and to develop innovative and thoughtful solutions to the crisis and challenge we are facing at local and international level.

The Council can play a role in directly reducing emissions through council buildings, housing, transport and land but it is also an essential player in shifting behaviour through supporting communities to act against climate change and setting standards for industry. Climate change will not be addressed through individual action alone but will also require significant change in our systems and infrastructure along with a lot more joined up thinking between different actors and areas.

I have tried to divide my submission more or less according to the headings within the plan. I wanted to highlight some aspects of the draft action plan which I think are particularly positive and could perhaps be scaled up in ambition while sharing some concerns and reservations around how the plan might be delivered. I have also suggested a few additional areas or actions for consideration.

I think it is particularly important to promote public innovation, community partnerships and projects which offer strong co-benefits; those that don’t just tackle climate change but also offer us cleaner air, safer streets, more accessible public spaces and a higher quality of life. 

I also believe we need to be very aware that we face twin and linked crisis in terms of climate change and the loss of biodiversity and that in planning how we address one we must always consider the other. 

Monitoring and Targets 

Through the creation of the Dublin Metropolitan Climate Action Regional Office (p.13), there is an opportunity to ensure that climate action takes a central focus in all of the council’s programmes. For this to be realised however, it is important that this office is adequately resourced with staff and support from the wider council.

While it is great to see the city setting itself targets, I believe the plan needs to be much clearer about how those targets are to be monitored and how baselines are set. While there is a detailed discussion in terms of baseline for climate adaptation there is far less information in relation to the baseline for climate mitigation and the reduction of emissions.   As it is currently drafted the plan does not make it clear what the baseline year is for targets such as a 33% reduction in energy use by 2020.  Clarity is needed in order to build public engagement and accountability around the achievement of these shared goals.  I would urge the council to make the scale and measurement of their ambition and targets transparent and accessible as possible.

Dublin could also seek to make practical monitoring links between the targets in this plan and local or national indicators in terms of the Sustainable Development Goals, which are a key global  framework for sustainability. CSO and Eurofound could be useful partners for the city on this? It may also be useful to monitor qualitative indicators on  cultural change and climate change awareness. 

Research and Public Awareness  (Participation and Partnership)
The plan highlights public awareness, however it could perhaps benefit from a stronger emphasis on public engagement and partnership.  Public awareness of climate change is in many ways ahead of our public institutions, as demonstrated by Eurobarometer research, the recommendations of the citizen’s assembly and the public campaigning on our streeets. The public will be the ultimate drivers and judges of this plan and it is important that their interest and ambition continues to be reflected in the strategy as it evolves. A commitment to ongoing public consultation is welcome however  it will be important to ensure that such consultation is meaningful and inclusive and that it allows space for the public to add relevant issues and ideas to the agenda and press for more ambitious action should that become necessary or possible. 

As well as providing space for individuals to contribue, active and ongoing engagement with civil society is essential.  As well as climate action campaigns and advocacy groups, it will be important to actively reach out to Dublin’s unions, sports groups, retirement associations and others who may not have climate change as a central concern currently.  This may require designated or ring fenced funding – in many community development projects for example, measures introduced under austerity have reduced their flexibility or ability to take on new projects – yet those spaces and projects are crucial to a just transition and to collective ownership of our city’s climate strategy.  While there is certainly a case for grant schemes and investment in new green businesses and social enterprise – it will also be important to ensure relevant resources reach existing community projects and support their engagement on environmental issues.   

In many case, it is community level initiatives which can deliver the greatest innovation. There is also great scope for partnership between local Dublin communities and public institutions  of higher education. European research funding is increasingly framed around environmental targets and the wider global SDGs and Dublin’s many universities and third level institutions are in a position to lead internationally.   It is very important that they work closely with the city, and that Dublin city also forms active partnerships with other cities. 

While businesses  play an important and dynamic role in relation to climate change, the greatest capacity for innovation is often in public research for public benefit, freed from the constraints of profit or patent. Public: public partnerships within and between cities across the globe will be key to achieving the innovation, scale and transferability we need to tackle the collective challenge of climate change.  

Energy and Buildings
Improving the energy efficiency of buildings owned and controlled by the council can and should be an early priority. 

Schools, libraries, sports and community facilities are important sites for retrofitting, renewable energy such as solar and the cultivation of biodiversity,  They also provide practical opportunities for young people to see and understand technologies and behaviours which enhance energy efficiency and increase understanding of biodiversity.

Improving the energy efficiency of council housing should be a particular priority given that it is directly within the remit of the council and offers many additional co-benefits for tenants such as improved quality of life and lower energy bills. The rate at which council housing stock is being retrofitted should be accelerated. This is one area where both national and European structural development funds might be accessed and increased. 

Properties that are currently under state or council ownership or being considered for sale and lease by Dublin City Council should, whereever possible, be maintained in public ownership. Where buildings are moved into private ownership the state loses an opportunity to control and continuously improve energy efficiency. There is need for longer term thinking in this regard. We cannot afford the kind of short term solutions represented, for example,  by recent proposals where the state might, via NAMA, sell publicly owned properties to private developers with the intention of those properties being subsequently leased back for social use.  If our housing strategy is to genuinely reflect our climate targets we cannot afford to cede decision making to the market, risking a minimal compliance culture.  While regulations may of course be set and enforced, publicly owned, delivered or administered developments have greater potential to go beyond the regulations and lead by example. 

Nonetheless, as the majority of people in Dublin live in privately owned and rented accommodation it  is also important that there are regulations in place as well as supports and incentives for those who would wish to upgrade the efficiency of their home – most especially renters who can be subject to higher energy fees or, potentially, carbon tax, should it be introduced. A potential means of addressing this is to make energy efficiency kits available freely to renters to improve their homes with energy efficient lighting, draught exclusion etc.  All those accessing annual fuel allowance in Dublin should also be offered practical supports around  insulation and retrofitting. 

With 33% of total Dublin emissions coming from commercial sources it is appropriate that the council would explore incentives and sanctions that could be introduced to promote energy efficiency of businesses, industries, and commercial property across the city. The draft plan should be revised to include consideration of how this might be best achieved.

Dublin previously showed leadership in terms of smokeless coal – it should again show leadership by seeking to limit or ban the use of LNG or fracked fuel. 

Resources
I have touched on other resource issues elsewhere in this submission but I wanted to highlight in particular the need for stronger strategic use of Public Procurement. The EU directives on procurement offer considerable, usually underused,  scope for a stronger focus on environmental considerations and climate targets within the preparation and criteria of calls for tender or contracts.  Dublin City could and should combine a lifecycle costing approach with a price:quality ratio approach with environmental and sustainability given a high weighting in the allocation of contracts, recognising and rewarding those businesses and suppliers who are delivering on best practice in this area.

One area of public procurement where far greater transparency is needed is waste management. Considerable damage has been done to public trust in recycling through a rolling series of scandals in relation to illegal or inappropriate waste disposal.  Moreover, the increased charges around green bins have reduced the comparative advantage which was for a time associated with recyclable packaging.  I believe the city would be better served if this crucial area was still subject to public delivery but failing that, far greater regulation, accountability and conditionality is required. 

Green and sustainable procurement will be particularly important in relation to the major projects earmarked for Dublin under the National Development Plan and I believe a very high weighting should be given to environmental and sustainability criteria in such contracts.

Moreover, all projects that are currently under consideration by the council should be subject to assessment for their climate impact, both risks and benefits, and prioritised accordingly.  The Royal Canal Greenway project is an example of an initiative which offers significant environmental benefits along with other co-benefits but been subject to multiple delays in terms of implementation and budget shortfalls.  Projects such as these which are already in the pipeline could be scaled up and delivered early in this strategy.

One very practical measure which the city could implement speedily is the roll out of Bottle refill stations across the city. Young people have shown leadership in this area by demanding refill stations in their schools across the country and it is important to follow their leadership in this area.

Transport
While moving towards an electrified fleet of vehicles for Dublin City Council is broadly welcome, there could be a wider aim of moving away from heavy motor transport wherever possible. Micro-mobility, including electric bikes and cargo bikes could play a greater role in public service as well as in private use.  Incentives and sanctions should be explored to reduce the volume of heavy traffic within the city and encourage greater public transport use as well as ‘active travel’ such as cycling and walking.

In addition to the environmental and climate benefits of active travel there are significant co-benefits in terms of public health, reducing congestion, improving road safety and reducing noise pollution in the city. 

The plans proposal for a “doubling of all active travel” (p.66) is, I believe, not ambitious enough. The  target set by the national cycling policy framework is 10% of all journeys to be made by bike and I believe Dublin, as a dense urban area, should aim for closer to 20%. The huge increase in bicycle usage following the introduction of the Dublin Bike scheme and the subsequent scaling up of that scheme is an indicator of the public appetite in this area and how ambitious we should be. There is a growing demand from the public for better and safer pedestrian and cycling infrastructure and supports, with a number of activist groups forming in different parts of the city. Residents want Dublin City Council to make active travel a viable and comfortable option for a wider demographic of people, including older people, those with a disability and young people commuting to school.

Initiatives such as the Green Schools Programme and Hike It! Bike It! Like It! Should be scaled up and rolled out extensively to help young people feel confident in using public space on foot or by bike. Investment in major projects such as the Liffey Cycle Route or Greater Dublin Cycle Network will also be key to transition and the achievement of our climate targets.  Another contribution to changing culture might be occasional car free days in the city which may encourage  those who do not otherwise feel safe to do so to come into the city and to cycle or walk safely in the streets. Pedestrian lights and adequate crossing time are also important in ensuring older people and those with a disability feel confident to tackle smaller journeys on foot. 

This plan is an opportunity for Dublin to learn from and build on on best practice from other cities across Europe. There may also be potential to access additional funding from funds such as EUInvest under the ‘sustainable infrastructure’ strand, not only in terms of pedestrian and cycling infastructure but also in terms of public transport. 

Public Transport is of course absolutely central to the achievement of our climate targets.  The value and benefit of any given public transport routes is not, for example, only in the level of use or the financial returns, it is also in the social connectivity and the potential for carbon reduction. A significant expansion of our public transport routes is essential, although environmental impact assessment must be part of that process. It is also important to ensure that public transport services are delivered in a low carbon and environmentally efficient way. This is one of the reasons that I strongly favour public rather then private delivery of new routes under the Bus Connect strategy. Publicly delivered services have an intrinsically greater flexibility to respond to new innovations or technologies in terms of carbon reduction.

Nature Based Solutions
We are facing a twin and linked crisis in terms of climate change and biodiversity loss and the solutions must also be entwined.  We need to reduce our carbon emmisions in a thoughtful way which also has regard for environmental impact. 

The All-Ireland Pollinator Plan 2015-2020 must be seen as an important accompaniment to Dublin Climate Change Action Plan. This plan identifies the importance of preserving wildlife corridors through urban spaces and protecting the green spaces and floral species which will promote insect and bird life. This plan, alongside the Dublin City Biodiversity Action Plan, is due for renewal in 2020. It is important that Dublin City increase its ambition for these plans in a way that is consistent with the urgency of the current climate crisis. 

We need to treasure and nurture all our cities green spaces. This not only includes our parks but also our roadside trees, our waterways, our allotments and even our  graveyards and historic cemeteries. These spaces are not only in terms of carbon capture but in terms of sustaining our natural and social ecosystems.  They also help to maintain cleaner air and improve the physical and mental health of people living in Dublin. 

Local community gardens and projects to support greater plant and wildlife within the fabric of the city should be supported and nurtured. Social and affordable housing and new public transport systems are a clear and urgent public priority  but green spaces are also important to sustainable communities.  While developing green sites may seem easier they employing compulsory purchase orders on neglected properties or challenging commercial development, it may not always be the best solution. 

Flood Management
Amongst the host of co-benefits green space offer to the city they hold a central place in flood management and climate action policy. Trees and green areas play a key roll in absorbing excessive rainwater. Our canals are also key in this regard and given the recent significant increase in development powers given to Waterways Ireland it will be very important that the city engage actively with that body.
Rpbust enviornmental impact assessment is essential to avoid inappropriate development on flood plains. Flood defences should also be designed in a way which also supports wildlife corridors and biodiversity.

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