South Dublin County Council Draft Climate Action Plan 2024-2029

The IGBC welcomes South Dublin County Council’s (SDCC) ambition to “meet, and surpass, 2030 national targets”, and SDCC’s commitment to renewable energy generation (E20), including Tallaght district heating system.

In relation to energy renovation, the IGBC welcomes the prioritisation of energy efficiency upgrades (E10) in areas that have been identified as being energy poor, as this should have the biggest impact on carbon emissions and support a just transition. The development of a tenant awareness toolkit is also key (E11), but engagement with tenants should start at an early stage in the process, and careful consideration should be given to how the information is presented and by whom. E.g., the Council may consider using videos and infographics. The person in charge of delivering the training/information to tenants should not only have technical skills, but also excellent communication skills to understand tenants’ needs, etc. It might be worth looking at the concept of “green doctors” which are used for some social housing renovation works in the UK.  

While we do understand the budgetary constraints that relate to energy renovation of the social housing stock, the Council must also lead by example in this area. This could include testing innovative ideas such as a greater clustering of projects to reduce costs (and engage with private homeowners), the introduction of a physical one-stop-shop (as done in Cork City with the Home Energy Upgrade Office) and the generalisation of post-occupancy evaluation (POE). The latter is key to ensure energy renovation perform as per design – hence delivering actual carbon savings, and to address any issues as they may arise. Better quality data on the impact of energy renovation works could be captured through the use of the Build Upon – Energy Renovation Framework, developed by the IGBC with input from Dublin City, Cork City, Laois and Kilkenny County Councils. The Framework allows local authorities to capture data on the environmental, social, and economic impacts of their energy renovation works.

The DZ and the City Edge Project provide a fantastic opportunity for SDCC to lead by example, and address both whole life carbon emissions in the built environment and transport emissions. The IGBC would like to encourage SDCC to trial innovative mitigation measures in these areas. E.g., a physical one-stop-shop for energy renovation in the SDCC, and greater clustering of renovation works. In relation to the City Edge Project, it will be critical to take a whole life carbon approach to cover not only energy efficiency of the building stock, but also embodied carbon emission and to get the planning right to ensure all developments are in walkable areas with access to high quality public transport.

On Whole Life Carbon Emissions, the IGBC welcomes the inclusion of actions E5 and E6 but believes that national coordination is required to develop a robust national methodology and benchmarks. As the IGBC, with support from the SEAI, is already working on the development of a national methodology, we would like to encourage the Council to engage with us to ensure that the methodology being developed suits your needs – Please see Appendix 1 for further information.

Feedback on training for elected representatives (Gov 1), Green Public Procurement (Gov 2) and assessment of SDCC’s projects (Gov3) is provided in the other section below, as these actions are included in each section.

While an estimated 99.3% of the emissions in South Dublin are outside of SDCC’s direct control, the Council can have a significant impact on the largest contributor to GHG emissions in SDCC (i.e., transport) through planning.

The draft Climate Action Plan includes many positive actions in relation to transport emissions, and a prioritisation of active and public transports. T10 is also highly welcomed to support the transition to greener urban areas, better public realms, and NBSs. However, the avoid-shift-improve approach could be much stronger, as SDCC could achieve so much through planning. While the transition to EV is important, the priority should be to reduce our reliance on private cars. To support this, the council should encourage, as much as possible, a better use of the existing stocks in central locations (including vacant and derelict buildings)[1] and ensure that no new developments are reliant on private cars.

Finally, while we welcome the inclusion of T24 and the objective of minimising the use of virgin materials in road construction projects, the IGBC believe that measuring the whole life carbon impact of road construction projects and prioritising them would be a better approach[2]. More specifically, we would like to encourage the council to apply PAS2080 as it also includes the increased (or decreased) emissions from road users.

[1] A co-benefit of this approach is that it would also reduce embodied carbon emissions. A recent report commissioned by the IGBC to Oliver Kinnane in UCD shows that the embodied carbon emissions of a deep residential retrofit is approximately a quarter of a new build. Kinnane, O. O. (2022). Whole Life Carbon in Construction and the Built Environment in Ireland - Today, 2030, 2050. Irish Green Building Council.

[2] See Whole Life Carbon in Construction and the Built Environment in Ireland - Today, 2030, 2050 section on infrastructure.

The IGBC welcomes the strong focus on Sustainable Drainage (SuDS) in the draft plan, and the overall objective of “managing rainfall more naturally” in the county.

While artificial areas increased by 16% in Ireland between 2000 and 2018, the publication of the “Householder’s Guide To Sustainable Drainage” and action F11[1] are extremely positive. However, SDCC could probably do more to raise awareness about the negative impact of soil sealing, and the benefits of SuDs. For instance, SDCC could encourage the use of the Home Performance Index, and more specifically indicator EN 3.0: Surface Water Runoff in all new residential developments. SDCC could also explore the “sponge city” concept as implemented in Copenhagen.

[1] The IGBC is setting up “Climate Safe Homes” working group to look at actions required to support better climate adaptation of Irish homes and would welcome SDCC’s input.

Given land use change is the main source of biodiversity loss and Ireland’s residential development patterns, addressing habitat destruction and fragmentation associated with our built environment is a priority. This section of the draft plan is comprehensive, and action N10 is extremely positive. The social housing estate could subsequently be used to raise awareness of the benefits of the approach[1]. The IGBC recently set up a community of practice on biodiversity in the built environment and would be willing to support SDCC with this initiative.

Beyond this exemplary project, more could be done to promote nature-based solutions at scale through planning. The latest version of the Home Performance Index includes a number of indicators for new residential developments which are highly relevant, i.e., ecology, land use, surface water runoff and climate risks.  

While the inclusion of a map of green corridors is extremely helpful, SDCC could perhaps do more to raise awareness about the importance of these ecological corridors, and of the role of private gardens within these corridors. This might help in raising awareness of the negative impact of soil sealing, etc.

Finally, it’s unclear to us why N12 simply mentions a “reduction of the usage of chemicals, such as glyphosate, across all council departments”. The objective should really be to eliminate the use of these chemicals[2].

[1] E.g., tours of the Vauban district are organised in Freiburg to allow visitors to gain a better understanding of the key characteristics of a sustainable urban district.

[2] See for instance France, where public bodies are no longer allowed to use chemical pesticides.

This section should focus more on construction and demolition (C&D) waste. The construction industry is extremely resource intensive, with 50% of all minerals extracted in the world used in this sector. C&D waste is Irelands largest waste stream, and this number is only going to increase due to the large amount of construction projects planned, especially under the Ireland 2040 plan.

While action R3 is welcomed, a stronger focus on the waste hierarchy (Prevent - Reduce - Reuse - Recycle - Recover - Dispose) is needed. More specifically, actions are required to support a better use of the existing stock[1], and to address derelictions and vacancy[2]. Likewise, new builds should be designed and built to support greater adaptability.

To reduce C&D waste, SDCC should also consider:

• Introducing financial incentives to support reuse and low carbon developments. This may include increasing levies on vacant properties, applying an additional planning levy (or increased rates) to new construction where major demolition is involved, or reducing planning levies for buildings of low carbon intensity (i.e., with 3rd party validated low carbon intensity as defined by benchmarks in RIAI climate challenge).
• Better supporting re-use of construction materials. E.g., through the development of storage facilities for large quantities of high-quality construction materials for reuse (materials exchange).
• Requesting pre-demolition assessments, presenting the environmental and economic case for repair or replacement. In cases where demolition is an appropriate course of action, request waste audits conducted by external auditors ahead of demolition to further support the mitigation of Construction & Development Waste (CDW).

[1] Could public buildings be used for longer hours and for different use? E.g., the University of Vrije in Amsterdam is developing a new building that can be used for teaching, research and cultural activities (as a cinema).

[2] The Whole Life Carbon in Construction and the Built Environment in Ireland - Today, 2030, 2050 report shows that the embodied carbon emissions of a deep residential retrofit is approximately a quarter of a new build.

The IGBC welcomes the strong focus of the plan on community engagement and collaboration with the Dublin Local Authorities, the Dublin Metropolitan Climate Action Regional Office, Codema – Dublin’s energy agency, and other neighbouring local authorities. Greater collaboration and consistency of approach among neighbouring local authorities is absolutely critical to address carbon emissions (especially carbon emissions relating to transport). However, the plan could be more specific on how this greater collaboration is envisaged.

All actions to support greater engagement with communities, including through support for Sustainable Energy Communities (CE10), are welcome. Ideally, these actions should be implemented alongside E10, i.e., to prioritise households at risk of energy poverty. This is key to deliver carbon savings and support a just transition. Using libraries as climate hubs (CE6) makes perfect sense, but the council could go one step further and use one of these libraries as a physical one-stop-shop to support people with energy renovation works and funding application as it has been done in Cork City. The IGBC has recently set up a residential renovation working group and the feedback we are getting is that while all the information is online, it’s challenging for some groups of society to access it (e.g., elderly people and time-poor households) and that physical one-stop-shop where people can access the information is useful. SDCC could also use their exemplary projects (e.g., district heating, action N10) to raise awareness about the benefits of energy renovation, decarbonisation of heating, NBSs, etc. Finally, if using the  Build Upon – Energy Renovation Framework to capture better quality data on the impact of its renovation projects, SDCC could incorporate the below dashboard (figure 1) in its Climate Action Website (CE8) to raise awareness of the benefits of energy renovation and share data on progress.      

The section on the decarbonising zone includes many interesting ideas (e.g., creating a regular drop-in ‘energy clinic’ where the public can receive advice on how they can take climate action, exploring possible links with Sustainable Energy Communities mentors, and developing a data gathering & monitoring project to track emissions and communicate progress[1]). However, a strategy is also required to implement these ideas at larger scale overtime.

Furthermore, the strategy for the decarbonising zone could be more ambitious. A comprehensive strategy that addresses all the emissions associated with the built environment across its whole life cycle would be most beneficial. This would cover operational emissions, as well as embodied and transport emissions (better planning). In relation to the latter, the focus on increasing permeability to encourage active transport is welcome, but more ambitious projects to address dereliction, vacancy and under-used buildings should also be considered. E.g., local authority buildings could be used as community spaces for groups participating in decarbonising zone projects, but also for other community groups’ projects and activities (hence reducing the need for new build). It would also be important to design and build for adaptability, and deconstruction to avoid waste. Exemplar projects focusing on circularity, reducing whole life carbon, etc. could be prioritized in the DZ and subsequently used to raise awareness about these issues (e.g., through open houses type of events).

[1] See previous section for an example of how the Build Upon Energy Renovation Framework Dashboard could be used.

Please find attached the EPA's Submission in relation to the Draft Local Authority Climate Action Plan and associated SEA Environmental Report. EPA SEA Submission - South Dublin Local Authority CAP 2024-2029

Corkagh Grange is pleased to see the details of the proposed plan, and hopes common sensibility will be adopted as common policy

CGRA would like to point out that the data used here is subject to change as models improve. Prudence suggest the plan aim to ameliorate a worst case scenario in all cases. It can be hoped that preventative measures will be out in place before another major Irish city floods. Where climate change is concerned, a broad scope makes sense 

CGRA notes the rather conspicuous absence of solar panels from the roof of most publicly owned buildings. New Perovskite crystal based solar panels will soon be commercially available. There will be no need for any economic concerns after widespread climate catastrophe, because there will be far more pressing concerns. So immediate action -now- is imperative 

CGRA notes that publicly owned housing estates don't tend to have EV charging points. Interdepartmental coordination toward this end would be greatly appreciated. The notionality of the idea is almost derisory, which highlights a problem with attitudes and dispositions, though the necessity remains paramount. Top down change tends to be slower than it's bottom up counterpart

CGRA representing the residents of Corkagh Grange notes that an opportunity for a case study presents itself on the form of the new estate. It was built on the roof plain on the Camac river which runs through Clondalkin, joining the Liffey near Heuston station. Officials, TDs, senators and local Councilors are regularly encouraged to visit the area.

Local flood defenses will be required as soon as possible as climate event frequency increases. The completion of the Camac flood alleviation scheme should be undertaken in liaison with locally knowledgeable interest groups and lifelong residents. We look forward to the final completion of the scheme and hope that it can be expanded in scope as conditions worsen

CGRA represents one of the only publicly owned housing estates in the country with solar panels as standard. This ought to be no more remarkable to people that a nice hat, but the very fact that there is a sense of novelty about this point should be cause for concern. It is the view of CGRA that every housing development in the country ought to have some renewable green energy capacity. Social attitudes towards the normalisation of a solutions based mindset should be forthrightly encouraged. 

Planning Ref:  FP2023-118

(Please quote in all related correspondence)

2 November 2023

South Dublin Local Authority Climate Action Plan 2024-2029

Senior Engineer,

Climate Action,

Environment, Water and Climate Change Department,

County Hall,

Tallaght,

Dublin 24

Via portal: https://consult.sdublincoco.ie/en/consultation/south-dublin-county-council-draft-climate-action-plan-2024-2029

Re: Notification under Article 28 (Part 4) or Article 82 (Part 8) of the Planning and Development Regulations, 2001, as amended.

Proposed Development: Draft Climate Action Plan 2024-2029

A chara

I refer to correspondence received in connection with the above. Outlined below are heritage-related observations/recommendations co-ordinated by the Development Applications Unit under the stated headings.

Nature Conservation

Having considered the Draft South Dublin County Council Climate Action Plan 2024-2029 and the Strategic Environmental Assessment (SEA) Environmental Report and Natura Impact Report (NIR) prepared in relation to this draft plan the Department makes the following observation.

The Department previously in August of this year made a submission in relation to the scoping of the SEA for the South Dublin County Council Climate Action Plan. In this submission corrections were suggested with regards to factual errors concerning the occurrence of protected plant species and the presence of a national park in the South Dublin County Council administrative area contained in Table 3.1 ‘Designated Ecological sites and Protected Species’ in Section 3.3 Biodiversity, Flora and Fauna of the scoping report. It is noted that these factual errors have not been corrected in the corresponding Table 4.1 ‘Designated Ecological sites and Protected Species’ in Section 4.3 Biodiversity, Flora & Fauna of the SEA Report prepared in relation to the Draft Climate Action Plan. It is therefore recommended that Table 4.1 in the SEA Environmental Report should be modified to incorporate the corrections with regards to the occurrence of protected plant species and the presence of a national park in South Dublin suggested in the Department’s submission on the SEA scoping for the Climate Action Plan.

Introduction

Community Gardens Ireland are a voluntary, independent, inclusive group that works with all agencies and groups that promote environmental awareness and support community gardening and food growing in all parts of the island of Ireland.

In recent years we have been heavily advocating for an improvement in legislation and policies for allotments and community gardens. In 2021 and 2022, we presented to Oireachtas Committees, including the March 2022 unique sitting on community growing in Ireland: 

https://www.oireachtas.ie/en/debates/debate/joint_committee_on_housing_local_government_and_heritage/2022-03-01/2/

At this meeting, we presented our Let's Get Growing report, which contained a number of recommendations for the Irish Government to improve legislation, set targets, and provide more protection and provision of allotments and community gardens in Ireland: 

http://cgireland.org/wp-content/uploads/2022/02/Community-Gardens-Ireland_Lets-Get-Growing.pdf

Community Gardens Ireland made a detailed submission to the Citizens' Assembly on Biodiversity Loss in the last year, and we were delighted when the following was added in to the final report: 

51. The State must ensure the expansion of community gardens and allotments through local authority initiatives in conjunction with private landowners, in both urban and rural communities.  

https://citizensassembly.ie/wp-content/uploads/Report-on-Biodiversity-Loss_mid-res.pdf

In April 2023, the Children and Young People’s Assembly on Biodiversity Loss also recommended the following: 

"28 Encourage people to grow more vegetables for themselves 

35 Make more green spaces in cities and urban areas" 

Link: https://cyp-biodiversity.ie/ 

In July 2023, Community Gardens Ireland made a submission to the national Climate Action Plan (Expert Evidence) calling for a number of changes, including for every climate action plan to include community growing as an action to be performed and for an increase in allotments & community gardens for each local authority. 

Review of Actions

Community Gardens Ireland notes that the 2024-2029 South Dublin County Council Climate Action Plan has deleted all mention of allotments or community gardens.

Community Gardens Ireland notes that the 2019-2024 South Dublin County Council Climate Action Plan mentions the following:

Council Allotments

There are 425 Council allotments at four locations across South Dublin, ranging in size from 50 square metres to 250 square metres:

• Tymon Park, Tallaght – 13

• Corkagh Park, Clondalkin – 39

• Friarstown, Bohernabreena – 297

• Mill Lane, Palmerstown – 76

The allotments benefit communities in SDCC by providing a source of affordable food and an opportunity for people to socialise. There are co-benefits for climate change adaptation, as these allotments absorb water that would otherwise run off into the drainage network

N26 Maintain and expand community gardens and allotments for local food production

Recommendations

Community Gardens Ireland recommend the following:

1) South Dublin County Council to immediately reinstate the wording and actions to maintain and expand community gardens and allotments for local food production from the 2019-2024 Climate Action Plan. The KPI for this will be the number (and increase in number) of allotments and community gardens in South Dublin County Council.

2) South Dublin County Council to commit to performing a review of idle, vacant and derelict land within South Dublin County Council that could be used for community growing purposes.

3) South Dublin County Council to commit to opening and supporting a seed library, similar to the one established within Wicklow County Council and in Hollyhill Library in Cork City.

***

Backup references:

Reductions in carbon and GHG emissions from community gardening

In the past, organisations such as the Scottish Allotments and Gardens Society have estimated the potential reduction in C02 emissions from community growing spaces. According to their document “Briefing paper on Allotments, Food and Climate Change: how growing one's own food can reduce emissions from food production”:

“If we assume that 25% of a plot-holders food is grown on their plots and there is a commensurate reduction in all bought food (but not in the domestic processing) then 4% (0.5 tonnes) of an individual’s total emissions will be saved each year. Surveys show that crops are usually shared by families, friends and local community groups. If we use a conservative estimate of two people benefiting, then at least 1 tonne of CO2 is saved by each standard allotment plot every year and a one hectare allotment site saves 50 tonnes of CO2 per annum.”

The Scottish Government also highlighted the reduction in carbon emissions from community growing, with estimates of between 2kg and 5kg of carbon equivalent for every kilogram of vegetable produced:

“Carbon emissions (including reducing energy use, more sustainable transport and less waste) can be reduced by between 2kg and 5kg of carbon equivalent for every kilogram of vegetable produced”

Ref: https://www.gov.scot/binaries/content/documents/govscot/publications/consultation-paper/2018/06/allotments-further-guidance-local-authorities-part-9-community-empowerment-scotland/documents/00537266-pdf/00537266-pdf/govscot%3Adocument/00537266.pdf

Intergovernmental Panel on Climate Change (IPCC) Report, 2019

A large argument in favour for the provision of more community growing spaces is that the spaces assist in the reducing of greenhouse gas emissions, improving urban food security, improving biodiversity and adapting to climate change impacts. In 2019, the IPCC released a report which included Urban Agriculture initiatives, as follows:

“Urban and peri-urban agriculture reduces the food carbon footprint by avoiding long distance food transport. These types of agriculture also limit GHG emissions by recycling organic waste and wastewater that would otherwise release methane from landfills and dumping sites (Lwasa et al. 2014). Urban and peri-urban agriculture also contribute in adapting to climate change, including extreme events, by reducing the urban heat island effect, increasing water infiltration and slowing down run-offs to prevent flooding, etc.

(Lwasa et al. 2014, 2015; Kumar et al. 2017a1209). For example, a scenario analysis shows that urban gardens reduce the surface temperature up to 10°C in comparison to the temperature without vegetation (Tsilini et al. 20151210). Urban agriculture can also improve biodiversity and strengthen associated ecosystem services (Lin et al. 20151211).”

“In summary, urban and peri-urban agriculture can contribute to improving urban food security, reducing GHG emissions, and adapting to climate change impacts (robust evidence, medium agreement).”

Ref: https://www.ipcc.ch/srccl/chapter/chapter-5/ 

Intergovernmental Panel on Climate Change (IPCC) Report – Working Group III, March 2022

Following the 2019 report above, the IPCC released their Working Group III report in March 2022. Detailed within this were climate and biodiversity actions related to increasing the amount of urban agriculture in urban areas, as detailed below:

D.2.1 Sustainable urban planning and infrastructure design including green roofs and facades, networks of parks and open spaces, management of urban forests and wetlands, urban agriculture, and water-sensitive design can deliver both mitigation and adaptation benefits in settlements (medium confidence). These options can also reduce flood risks, pressure on urban sewer systems, urban heat island effects, and can deliver health benefits from reduced air pollution (high confidence).  

8.1 Sustainable Development: Urban agriculture, including urban orchards, roof-top gardens, and vertical farming contribute to enhancing food security and fostering healthier diets.  

8.2.2 Economic development, competitiveness, and equity: Urban agriculture can not only reduce household food expenditure, but also provide additional sources of revenue for the city.  

8.4.6  Urban-rural linkages: Urban food systems, as well as city-regional production and distribution of food, factors into supply chains. Reducing food demand from urban hinterlands can have a positive impact on energy and water demand for food production (Eigenbrod and Gruda 2015) (see ‘food system’ in Glossary). Managing food waste in urban areas through recycling or reduction of food waste at source of consumption would require behavioural change (Gu et al., 2019). Urban governments could also support shifts towards more climate-friendly diets, including through procurement policies. These strategies have created economic opportunities or have enhanced food security while reducing the emissions that are associated with waste and the transportation of food. Strategies for managing food demand in urban areas would depend on the integration of food systems in urban planning. 

Link: https://www.ipcc.ch/report/ar6/wg3/downloads/report/IPCC_AR6_WGIII_FullReport.pdf

World Health Organisation recommendations for public green spaces

The World Health Organisation included reference to allotments and community gardens in their publication “Urban green spaces: a brief for action”. In addition, they recommend the following:

"As a rule of thumb, urban residents should be able to access public green spaces of at least 0.5–1 hectare within 300 metres’ linear distance (around 5 minutes’ walk) of their homes."

https://apps.who.int/iris/bitstream/handle/10665/344116/9789289052498-eng.pdf?sequence=1&isAllowed=y

This submission is made on behalf of Not Here Not Anywhere. Not Here Not Anywhere is a nationwide, grassroots, volunteer group campaigning to end fossil fuel exploration and the development of new fossil fuel infrastructure in Ireland. We advocate for a just transition to publicly-owned renewable energy systems and a society-wide reduction in energy demand both here and around the world. We are a non-partisan group and are not affiliated with any political party.

We applaud the actions proposed in the Draft South Dublin County Council Climate Action Plan in order to achieve the vital target of reducing greenhouse gas emissions by 51% by 2030. In particular, we approve of the following commitment “Significant electricity consumers, such as data centres and other large industrial sites, should maximise on-site renewable generation and ensure any remaining demand is supplied through renewable Power Purchase Agreements (preferably those which match hourly site demand), which finance renewable electricity projects within Ireland or its territorial waters.”

1. Fossil fuels and fossil fuel infrastructure

Recommendations for additional actions:

• The Climate Action Plan should ensure a rapid phasing out of all fossil fuels including gas.
• The Climate Action Plan should include a planned phasing out of existing connections to  the gas grid.
• The Climate Action Plan should ban fracked gas in its energy mix.
• The Climate Action Plan should  rule out any new fossil fuel infrastructure projects. 

Impacts of Fossil Gas Projects

Research states that if we are to keep global temperature rise below 1.5°C and avoid catastrophic climate change, fossil gas must be phased out of the energy mix in Europe by 2035 (Anderson & Broderick, 2017), discrediting claims that gas is a "transition fuel" in the transition to a decarbonised economy (Borunda, 2021; Hmiel et al., 2020). Research also states that we can’t develop any new fossil fuel infrastructure from 2019 onwards if we are to have a 64% chance of limiting temperature rise to less than 1.5°C (Smith et al., 2019). Any new large-scale fossil fuel infrastructure must be ruled out, as they will lock us into additional use of fossil fuels. Further investment in fossil infrastructure will close the window on meeting our obligations under the Paris agreement and the county’s and Ireland’s legally binding targets, rather than getting us closer. 

Energy Security and Fossil gas

New fossil fuel infrastructure is sometimes justified with references to the need to increase Ireland’s energy security. For example, operators of data centres have been applying for planning permission for diesel and gas generators, sometimes entire gas power plants (MacNamee, 2023a). Notably, the energy security risks associated with continuing climate breakdown, through fossil gas emissions, are often not considered in such discussions. 

New gas infrastructure is not required for energy security. A 2020 study by leading independent consultancy, Artelys (2020) concluded that “existing EU gas infrastructure is sufficiently capable of meeting a variety of future gas demand scenarios in the EU28, even in the event of extreme supply disruption cases”. The European body of gas network operators, ENTSO-G, in its 2017 Security of Supply Review, found that Ireland and the UK would suffer no curtailment in gas supply if faced with a variety of supply disruption scenarios. Historically, the UK has provided most of Ireland’s gas supply, and Ervia states that in the UK “there is ample import capacity over and above demand” (Ervia, 2018). Demand for gas in the UK has decreased by a fifth since 2004 and gas-fired electricity generation is expected to drop by 40% by 2025 (Evans, 2019). This is due to the existing over-capacity of the EU gas grid; gas import infrastructures have import capacity 200% higher than what Europe actually imports (Gaventa et al., 2016).

As outlined in the Draft Climate Action Plan, we are legally bound to emissions-reduction targets under the Climate Act, 2021, which is fundamentally incompatible with increasing investment in new fossil fuel infrastructure. Therefore, the best energy security remains a rapid transition to indigenous renewable energy and a society-wide reduction in energy demand.

2. Energy - A better way forward

Recommendations for additional actions:

• The Climate Action Plan should include actions which incentivise community energy projects - community based projects, organisations and social enterprises involved in the energy sector, owned and operated by local people and local authorities in the community
• The Climate Action Plan should prioritise safeguarding against Energy Poverty
• The Climate Action Plan should contain measures to ensure that energy demand is managed responsibly and sustainably, with energy seen as a public good whereby essential services are prioritised. This should involve rapid retrofitting and the decarbonisation and increase of accessibility of public transport.
• When introducing community energy projects or new energy infrastructure, decision processes should be designed in a participatory way, with input from residents and stakeholder group representatives. Special outreach efforts must be made to include disadvantaged or marginalised groups in participatory processes. Those running participatory processes should keep a detailed record of the participation of marginalised groups and of best practices that serve to increase this participation.

Public and Community Ownership of Energy

We must reimagine and rebalance energy ownership, transitioning away from the current developer-led for-profit approach. Energy democracy includes both state and community ownership. Ireland is very suitable for state ownership of renewable energy resources, with a state-owned grid and major semi-state organisations such as ESB and Bord na Móna. Appropriate governance structures should be put in place to ensure these organisations are accountable to the public. Community energy consists of community based projects, organisations and social enterprises involved in the energy sector, owned and operated by local people and local authorities in the community. The Climate Action plan should add actions which facilitate local communities and organisations to invest in their own renewable energy infrastructure, through providing expertise and financial incentives or support. Denmark and Germany, where wind and solar energy were scaled up rapidly, have the highest levels of local and community ownership in Europe. Local energy also strengthens local economies. By avoiding large financial outflows from local economies to pay for external fuel and external energy, more financial resources are retained and circulated in local economies.

Eliminate Energy Poverty

Energy systems should be set up in a manner that addresses energy poverty and is inclusive of marginalised groups. In November 2022, an ESRI conference revealed that 40% of Irish households were experiencing energy poverty. Marginalised groups are disproportionately vulnerable to energy poverty. The Climate Action Plan should include measures to ensure costs are kept to a fair level. For example, housing stock should be retrofitted rapidly. Energy has to be seen as a human right and should not be subject to price hikes for company profits.

Reduce Energy Demand

Energy demand should be managed responsibly and sustainably, with energy seen as a public good whereby essential services are prioritised. This should particularly target large energy users, who are often private corporations (such as data centres) who provide no transparency about the need for their energy demand, beyond profit maximisation. Energy reduction should happen equitably, without disadvantaging vulnerable members of society. Economic models should be adopted which ensure quality of life and equity for our societies, and also reduce demand and consumption in certain sectors.

The Climate Action Plan should also include an accelerated program of retrofits and solar PV for all households and community buildings, on a government-run “install now, pay as you go” basis, so that having cash up-front is not a barrier. Electrification of and improvement to frequency and accessibility of public transport (rail and buses), promotion of active travel, promotion of car sharing, and reduction in use of private cars particularly with single occupancy.

3. Data Centres

Recommendations for additional actions:

• The Climate Action Plan should add as an action the setting of an overall cap on the level of data centre energy demand that can be accommodated by the electricity grid in the county.

• The Climate Action Plan should specify that new and existing data centres are required to provide flexibility to the grid at times of day and times of year when wind and solar energy on the grid is low relative to demand - and not allowing data centres to use fossil fuel generation as the means of providing this flexibility (they can use other means e.g. energy storage, time-shifting of data processing services).

• The Climate Action Plan should specify that new data centres are required to be powered entirely by one of the following, and existing centres should be required to transition rapidly to:
  • On site direct renewable power source generation combined with energy storage, or
  • Off site renewable power source and energy storage with dedicated grid connection (avoiding Renewable Energy Certificates).  
  • Any renewable energy infrastructure must comply with best practice public participation.

• New data centres should have infrastructure in place to enable heat generated from them to be utilised for district heating systems.

The government has acknowledged that “data centres pose considerable challenges to the future planning and operation of Ireland’s power system” (Department of Business, Enterprise and Innovation, 2018). As of 2022, data centres accounted for 18% of Ireland’s electricity demand, the same amount as all urban homes (CSO, 2023). Going forward, Eirgrid estimates that data centres could account for up to 27% of Ireland’s electricity demand by 2028,  and up to 50% of new electricity demand growth (Eirgrid, 2020). The Irish Academy of Engineering predicts that data centre development will add at least 1.5 million tonnes to Ireland’s carbon emissions by 2030, a 13% increase on current electricity sector emissions, and will require an investment in energy generation and storage of €9 billion by 2027 (Irish Academy of Engineering, 2019). 

For example, if Amazon’s eight centre project in Mulhuddart, Dublin 15, is realised, by 2026 it would use c. 4.4% per cent of the State’s entire energy capacity, the equivalent of Galway city, but employ only 30 people post-construction, largely in facility maintenance (Lillington, 2018). The Apple data centre proposed for Athenry, Co. Galway, would have ultimately used “over 8% of the national capacity…, more than the daily entire usage of Dublin, and “would require 144 large diesel generators as back-up” (Climate Home News, 2017).

Therefore, in a recent policy statement, the Irish government admitted that “In the short term, there is only limited capacity for further data centre development” (Department of Enterprise, Trade and Employment, 2022). These challenges include higher electricity costs for consumers (Taylor, 2018). In 2019, the Danish Council on Climate Change recommended that the Danish government legally requires data centre owners and developers to contribute to the infrastructure required to supply the centres with renewable energy, such as wind and solar farms (Irish Examiner, 2019). Polling has shown that the majority of Irish people (59%) believe that data centres should be restricted to achieve climate targets and to reduce strain on the grid (Business Post & REDC, 2021).

Currently, data centres use onsite fossil fuels generators to supply electricity at times of high electricity demand from the grid, during maintenance, or when renewable energy cannot provide enough electricity due to its inherent variability.  Irish data centres now already have enough on-site power to meet all of Ireland’s energy demand, indicating the scale of their additional energy consumption (MacNamee, 2023b). However, sufficient provision of electricity should not be guaranteed by relying on fossil fuels which further exacerbate climate change and again put the meeting of emissions reductions targets specified in the Draft Climate Action Plan at risk. Instead, the applicant should be required to install renewable and clean energy back-up and storage, for example with battery storage sufficient for any back-up and emergency power generation requirements.

Thus, the Climate Action Plan should specify a cap on the operation of (new and existing) data centres based on its emissions targets and their emissions, and require new and existing data centres to be run on renewable energy

Currently, many companies claim to operate data centres powered by 100% renewable energy. However, the energy is largely sourced indirectly through Renewable Energy Certificates or Purchase Power Agreements (Chernicoff, 2016), which means that the energy is sourced from the grid, which in Ireland is 69% fossil fuel-powered (Sustainable Energy Authority of Ireland, 2019). If we continue to allow companies to virtually purchase clean energy where it is cheapest to create, while actually using and increasing demand for dirty energy in Ireland, we allow them to profit while our real emissions continue to rise. It is crucial therefore that data centres are powered directly by onsite renewable energy generation such as rooftop solar farms or genuinely new offsite generation such as offshore wind or solar farms. 

Data Centres and Energy Security

It should be emphasised that the risks posed to Ireland’s energy security, as outlined in Eirgrid’s All-Island Generation Capacity Statement, are largely a result of an enterprise strategy that allows for unsustainable data centre demand growth. If the county council permits data centres and facilitates this growth in electricity demand by data centres, this will prevent the council meeting its emissions reductions targets in the Climate Action Plan. Furthermore, it is crucial that every City and County Council takes into consideration the cumulative impact of data centres’ energy demand on a nationwide basis, as opposed to examining impact solely on a case-by-case basis. 

Data Centres and Transparency

Data centres provide a wide range of services, but are not transparent about the amount of energy used for these different purposes. While some capacity provides essential services to society (enabling public services like health, public transport, remote working, and communications between people), at the other end of the spectrum are services that can be seen as highly wasteful, such as cryptocurrency mining. An independent report into organisational data management also demonstrated that a majority of data stored globally is dark or redundant data, while only 14% was business-critical (Veritas, 2015), meaning that energy used for its storage is essentially wasted.

To make a case for the construction of the data centre, which will create further electricity demand and therefore challenge the realisation of Ireland’s decarbonisation targets, the Climate Action Plan should require that data centre applicants provide information about the purpose or their services, and how they will ensure electricity is not wasted on storing dark or redundant data that have huge costs to our energy infrastructure without providing societal or commercial benefits.

Waste Heat

Data Centres also generate large quantities of waste heat which could be utilised in district heating systems (Ramboll Group, 2019). Existing technology (such as heat pumps) to capture excess heat should be required and used to increase data centres’ energy efficiency. The Climate Action Plan should require that data centres are only granted planning permission if they provide infrastructure to recover and utilise waste heat. This may require only granting data centres planning permission adjacent to where district heating systems are located.

Conclusion

We applaud the County Council for its ambitious actions specified in the Draft Climate Action Plan. In our submission, we have outlined actions we believe add to the existing plans in order to fulfill the commitments to climate action and emissions reduction targets, thereby safeguarding the county’s and Ireland’s citizens, nature, and climate.
 

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People Before Profit is an eco-socialist party that understands the necessity of urgent action to tackle the climate crisis. We believe that this must be done in a way that puts the burden on the major corporations and polluters rather than ordinary people.

The party has comprehensive Policies on Environment, Energy, Waste Management and Water.

While our policies contain proposals for actions that could be immediately taken to reduce carbon emissions we believe that to keep temperature rise to below 1.5 degrees we need more fundamental change. We need to change our economic capitalist system, that puts profit ahead of everything else, to a socialist system based on catering to the needs of people and the environment.

The South Dublin County Council Draft Climate Action Plan 2024-29 seeks to provide a plan for tackling climate change within the perimeters of the current economic system and government policies.

While People Before Profit believe that this will not work in the long run we welcome that there is a plan and we will outline some proposals that we have to improve it.

We recognise that over 99% of emissions in the South Dublin County Council area are not within the control of the council itself. This is a consequence of neoliberal policies of outsourcing and privatisation which has decimated local authorities. However, the social housing stock owned by SDCC should be included in the calculations for the SDCC emissions. It’s completely unrealistic to expect tenants to make the necessary improvements to their homes.   

We in People Before Profit are very concerned to see that data centres are now responsible for 32% of all carbon emissions in the county. We want to re-iterate our call for a complete ban on any new data centres in the county. The Minister’s decision to overturn the ban agreed by councillors in the Development Plan was not only undemocratic, it was outrageous.

The public lighting LED programme has been a great success and it’s welcomed to see that the programme will continue.

The retrofitting of council homes needs to be prioritised and the current funding provided by government is not adequate. The 441 homes completed by 2024 and even the 500 homes per year target are woefully inadequate. We need much more ambitious targets in order to reduce emissions and improve peoples’ homes. If the government does not provide adequate funding for an upscaled programme, then the council should look at funding this programme through its own resources. An increase in rates for large businesses, as has been proposed by People Before Profit councillors, could provide additional funding for this.

There should also be a consideration of installing solar panels on council homes as a more immediate measure for homes not scheduled for retrofitting in the near future.

People Before Profit welcomes the use of district heating as a heat source for homes and public buildings. Considering the large number of data centres in Grange Castle there is potential here for a significant district heating system. This needs to be planned with the utmost urgency to allow the new homes in the Clonburris SDZ to avail of this system. It would make sense to pout the plans for this in place before the construction of houses here, or at least to ensure through the planning system that homes will be ready for district heating when it is developed.  However, we have concerns about private companies having control over our energy and think SDCC needs to consider what would happen if the data centre closed shop.

Only a small amount of the total emissions from transport is generated by SDCC directly. Transport emissions in the SDCC area are very high predominantly due to the use of the private car. Unfortunately many of the areas were built and designed in a way that makes people more reliant on cars. For example, many estates in Lucan have no direct pedestrian access to main roads with bus stops and there is virtually no cycling infrastructure.

Public transport is key to reducing emissions. Unfortunately, the council has no control over the public transport service which comes under the remit of the NTA. At the moment there are significant issues with both buses and the luas. The red luas is often full to capacity and it’s becoming increasingly unreliable. The bus service has been plagued by driver shortages, ‘Ghost buses’ and capacity issues. These problems need to be addressed by the NTA urgently if we want to encourage more people to use public transport. People Before Profit is also calling for the introduction of free public transport which would require additional investment to implement.

In terms of cycling and walking, there has been some improvement in recent years with better infrastructure and the Cycle South Dublin plan. Again, we need to see more investment and a re-thinking of the infrastructure. We need complete cycle lanes with designs that allow for completely off-road segregated cycling to enable safe cycling for all. There are still many main roads that are completely unsafe for cyclists. One example is the Newcastle Road in Lucan from Adamstown to Lucan Shopping Centre. This is not part of the Cycle South Dublin programme but is urgently needed to reduce traffic here.  

The issue of climate change and urban flooding is a very real and immediate problem facing the council and the constituents. We can see this in flooding events in areas of Ireland such as Middleton.

Because a certain degree of climate change is now baked in to the climate system already there is an urgent need for the council to look at climate adaptation in the Climate Action Plan for the county. This must be matched with an urgent decarbonisation and radical action on emissions in the county.

The Draft Climate Action Plan makes some good points about adaptation, and nature based solutions to adaptation. However, these are extremely general and unspecific. It is the view of People Before Profit that we need to see much more specific detail on what kind of nature based solutions, and other climate adaptation measures the council executive are proposing, and where these actions will occur.

It will be essential for the council to do this because there is a danger of being left open to accusations of greenwashing if the Climate Action Plan is perceived to contain low or ambiguous targets and proposals.

Overall we believe that the council needs to prioritise nature based solutions to help deal with flooding issues in the county.

The Integrated Constructed Wetlands are a great example of nature based solutions that can reduce flooding and provide enhanced biodiversity.

We also welcome the Sustainable Drainage Guides for developers and householders as part of moving away from hard surfaces in our residential areas and reduce flooding.

People Before Profit welcomes the positive work that has been carried out so far by SDCC to tackle the biodiversity crisis. The wildflower meadows and reduced grass cutting in parks and open spaces make a huge difference and is welcomed by communities.

We believe that the ending of the use of glyphosates for weed control must be a priority. Glyphosates are extremely harmful to the environment and human health and should be banned completely. This would require investment in alternative solutions such as increased staff for manual weeding using other methods.

The privatisation of waste management has been a disaster. It has led to significant levels of dumping and high costs for households. It also makes it more difficult to control what happens to our waste when it is collected.

People Before Profit want the renationalisation of waste management and for it to be returned to local authorities. This would give local authorities more control over waste and measures to reduce waste.

We welcome the concept of the circular economy, however the actions proposed are extremely limited. As long as we live in a capitalist society big business will continue to produce goods with “built-in obsolescence” and make it more difficult to repair products in order to force us to constantly purchase new goods.

Despite this, we think that there is potential for projects to promote the circular economy such as working with local Traveller groups to bring back old traditions in the community of repair and reuse. People Before Profit have been arguing for an SPC sub-group to specifically focus on the Circular Economy.

The Department of Public Health Dublin and Midlands welcomes the South Dublin County Council (SDCC) Draft Climate Action Plan 2024-2029. We appreciate the opportunity to provide feedback on the plan. We have structured this submission to mirror the sections outlined in the action plan.

Overall, the actions outlined in the plan have the potential for co-benefits on the mental and physical wellbeing of the residents of South Dublin and beyond. It is important, however, that radical and rapid implementation of climate action is achieved.

The climate crisis is a public health crisis. Burning of fossil fuels contributes to increases in stroke, heart disease, lung cancer and COPD. Approximately 1,300 premature deaths could be prevented every year on the island of Ireland if air pollution levels were kept below the recommended World Health Organization (WHO) upper limit. Furthermore, extreme weather events can result in death, illness and damage to essential infrastructure, including healthcare facilities. Climate change impacts on the social determinants of good health, such as employment, food security, housing, social inclusion, and access to health services. Its effects have the potential to widen the health gap and worsen health inequities and inequalities in our society. Globally, we have seen climate change disproportionately affect those who are least able to absorb the impact. We suggest that SDCC ensures equity is enshrined as a guiding principle throughout the action plan. This approach will be more successful in mitigating the impacts of climate change and in achieving a just transition.

We suggest that the climate action plan ensures future sustainability in achieving emissions targets. Population growth through natural change (birth and deaths) and migration is expected to increase emissions in the SDCC area. Currently, the Environmental Protection Agency (EPA) estimates that emissions per capita are 11.9 tonnes CO2eq/person. The global effects of climate change have the potential to result in mass inward climate migration, and plans should consider the projected emissions effects of these changes. Furthermore, incremental design should be considered to ensure that the plan progresses in line with most up-to-date international and national legislation as they evolve, and achieves the outlined reduction in emissions targets at a minimum, if not exceeding them.

• We welcome the detailed and guideline-based approach to the SDCC climate change risk assessment, outlined in the action plan.
• We note that the risk assessments refer in the main to the impacts of identified climate change hazards on the delivery of services by SDCC. We support the detailed consideration of this perspective as it informs future preparedness and planning.
• We would also welcome reference in the plan to the potential impacts of the identified hazards on the population of South Dublin. There are some direct and indirect references in this regard on page 41 in the box detailing the assumptions made in relation to areas of impact. However, this could be expanded upon further.
• Greater clarity in the risk assessment matrices on pages 39 (Fig. 3.7) and 42 (Fig. 3.9) would be welcome in relation to whether the impacts on the Y axes refer to those affecting the population or affecting service provision by SDCC.

• We welcome the plans for retrofitting social housing described in this section. As well as reducing emissions, this will hopefully alleviate energy costs for residents of social housing.
• As stated in the risk assessment on page 40 of the action plan, heatwaves are projected to become frequent due to climate change. Furthermore, rainfall and storms are also projected to become more likely. Resilience to heat, drought, floods and storms should be considered in building design and planning. For example, building standards should incorporate design measures to minimise the risks of buildings overheating. Heat stress and increased risk of Legionnaire’s disease are potential health consequences associated with the overheating of homes and other buildings. Shaded outdoor areas such as tree cover should also be incorporated into development planning to reduce the impacts of heatwaves. The value of residential gardens and avoidance of soil trapping should not be underestimated and should be considered in urban planning decisions.
• There is a need to build an adequate supply of climate resilient, zero-carbon housing, in line with projected population increases and housing demand increases. Development planning in the context of climate change should consider the needs of the most vulnerable populations in the county, such as people experiencing homelessness or those experiencing deprivation.

• We support exploring and scaling up further innovative solutions to avoid heat waste. It is striking that data centres in South Dublin are responsible for 32% of emissions in the county as stated on page 33 of the action plan.  We support the development of the district heating schemes, which take waste heat from commercial data centres and similar large operations and redirect it to nearby buildings. In addition, all planning considerations for future data centres should examine their net impacts on emissions, and be contextualised in terms of the emissions targets for South Dublin before planning is granted. There should also be a requirement for existing data centres to become fully operational using only renewable energy sources.

• We welcome the positive actions in relation to increasing active travel and public transport networks, including the progression of cycle South Dublin. While the actions outlined around transitioning to electric vehicles would hopefully reduce vehicular emissions, the focus should be on reducing overall dependence on private transport. Active travel targets both the climate (including air quality) and obesity, two public health crises. Those who participate in travel via cycling or walking could potentially reach or exceed the WHO physical activity targets through active travel alone. Active travel networks should also be considered and implemented in the planning of all new public amenities or housing developments.

• Children are particularly vulnerable to air pollution. This is related to multiple factors such as their higher respiratory rate, higher air intake per kg of body weight, and higher fraction of oral breathing. Due to their height, they also breathe air closer to the ground, where vehicle exhaust fumes are emitted and accumulate. Children’s lungs and immune systems are still developing which further increases their risk. Those sitting inside a car are exposed to much higher pollutant levels than those outside. Poor air quality not only increases the incidence of respiratory illnesses, such as asthma and infections, but also has been linked to poorer academic performance. We support the focus in the plan on reducing specific barriers for children to participate in active travel, including cycle safety programmes.
• However, we suggest a more ambitious approach to safe walking and cycling infrastructure, including more detailed plans for increased access to safe, continuous, segregated cycle and walking infrastructure. We also suggest that progress on increasing the cycle network not only be in measured in the number of linear metres added but also in connectivity to existing infrastructure, and number of kilometres that are fully segregated.
• The European Environment Agency recommends the establishment of ‘clean air zones’ around schools to reduce the concentration of pollutants found there. Lower pollution levels can be achieved through restrictions on traffic, such as no-idling zones around schools, ‘school streets’ (i.e. with a traffic ban at the start and end of the school day in the immediate vicinity of the school), or relocation of drop off/pick up points away from school entrances. We would welcome this consideration in the Climate Action Plan as a nudge away from private transport towards more active travel.
• We would like to see the action plan include the introduction of restrictions to private transport in urban centres, and concurrent development of bus networks and park-and-ride options.

• We welcome the key action areas outlined to support resilience to flooding in South Dublin, including adaptation to flood events. Flooding has a wide range of direct and indirect impacts on human health, both physical and mental. Flood events can cause physical illness (e.g. due to infection from contaminated flood water), injury and loss of life. Mental health can also be significantly impacted, in the short- and long-term, by such events. Indirectly, flood events can affect health and wellbeing through disruption of essential services, and damage to critical infrastructure (e.g. roads, water supply, access to healthcare, and wastewater treatment systems).
• We suggest special consideration should be given to healthcare settings and facilities in the context of flood resilience and response e.g. primary care centres, hospitals, and residential care facilities. These structures are vital for human health and provision of essential services in the event of flooding, and by definition have vulnerable populations on-site.
• We suggest a database should be considered for the tracking of climate-related impacts affecting South Dublin – as mentioned in our comments on the climate change risk assessment outlined in the plan, this should consider impacts on the local population.

• We support the actions outlined to preserve and increase biodiversity in South Dublin. This will have co-benefits such as reducing the urban heat island effect and promoting human physical and mental health. We suggest ensuring these green spaces are also used as public amenities where possible, e.g. providing benches, waste facilities etc.
• We are supportive of the Dublin urban rivers LIFE project to improve water quality and the continuing domestic misconnection inspections. Industrial misconnections also need to be systematically identified and rectified by relevant statutory agencies in accordance with wastewater regulations.
• While we support the planting of native trees, we would like to see protection and enforcement of established trees enhanced in this plan. Established route systems and canopies of trees are better able to contribute to biodiversity, heat protection, improved air quality, noise reduction and carbon sequestration but also have the co-benefit of promotion of mental and physical health.

• We acknowledge the importance of waste management for public health including reducing pollution and associated vermin which can be vectors of infectious disease. We support the plan for increasing opportunities for recycling and all efforts to promote reduced consumption.

• We suggest promoting recycling/reuse initiatives to local businesses, including encouraging supermarkets and restaurants to reduce food waste, especially via initiatives that have co-benefits on alleviating food poverty. Organic food waste bins should be made available to everyone in South Dublin. Waste companies operating in the area should disincentivise use of the black bin (waste going to landfill) wherever possible.
• In terms of material waste, we appreciate the efforts of local authorities to recycle materials such as clothing. This should be extended to rags with dedicated efforts to textile recycling to reduce landfill use.
• We encourage the exploration of innovative solutions to waste management, for example, the use of biomethane (a by-product of food waste) as a source of energy.

The emissions profile highlights how electricity use for street lighting makes up half of the energy used by SDCC. It is also stated that this electricity use accounts for much of the Greenhouse Gas emissions from SDCC. However this assumes that the electricity is produced with fossil fuels. This will change over time and thus it is important to focus on the direct emissions for which SDCC has responsibility i.e the fossil fuels used in buildings, transport and machinery use. That said the use of diesel propelled vehicles and machinery may far more economic in the short term given that the actual number of motors involved is small and the benefits in terms of public realm and roads/footpaths and bike lanes are immense.

A big issue for the Social Democrats is that even though SDCC own over 10,000 social housing dwellings, the energy and emissions profiles from same are disregarded in this Climate Action Plan. This mean that this is a case of the classic economic problem, the principal agent dilemma, whereby in this case, the landlord has no motivation to improve the efficiency of the dwellings as he does not pay the energy bills, while the tenant for the most part cannot afford to make the necessary investment and anyway cannot access SEAI grants. Given that SDCC are the current pioneers of District Heating in Ireland, one way this matter could be addressed is to conduct system level studies to investigate which would be cheaper - to roll out a district heating network to provide heat in social housing or on the other hand to retrofit the same social housing dwellings. If a district heating network would be cheaper and easier to implement maybe this is the solution to reduce the use of fossil fuels in Social Housing, and at the same time improve comfort and air quality.

The spate of flooding in Ireland in Autumn 2023 is literally bringing climate change home to people. In this regard it is exemplary that the various flood alleviation schemes on the rivers of SDCC  are already underway. However more could be done to highlight this work and it's benefits and attempt to get more engagement. For example there is almost no awareness among the general public of how increased paving/cobblelocking of driveways and back gardens causes more water to run into the storm water system thus putting more water into the same rivers. Homes that are currently in areas with risk of flooding are finding expensive insurance premiums and thus they could benefit economically from flood alleviation schemes changing the flood status of their area. This is more reason to highlight these schemes to the general public.

The single biggest climate action that SDCC could take is to roll out cycling infrastructure across the county. The vision of Cycle South Dublin is great but there does not seem to be adequate staff employed to implement it. The Greater Dublin Area Cycle Network Plan is even more ambitious but far from being realised. SDCC's own research shows that there is a significant percentage of the population that would cycle if they thought that it was safe. Such a modal shift would reduce regional emissions and congestion. A new motivation to roll out cycling infrastructure is to provide space for e-scooters which are currently using footpaths and unfortunately causing some nuisance there to pedestrians. E-scooters are cheaper to run than cars, have far lower emissions and lower ecological footprint and ecological rucksack than cars, and also take cars off the road. Thus an extensive protected cycling network can achieve many goals simultaneously.

Introduction

The Four Districts Woodlands Habitat Group (FDWG) welcomes the opportunity to participate in the public consultation on the South Dublin County Council Draft Climate Action Plan 2024-2029 (Draft CAP 2024-2029).

We commend the Council and Codema staff on the public consultation held in Clondalkin Civic Offices. They were excellent, polite, knowledgeable, courteous and enthusiastic.

We congratulate the Council on their actions taken to date to lower the carbon footprint of their activities. We note the continued efforts outlined in this draft CAP.

We welcome the addition of a specific section on community engagement in this draft CAP. 

We acknowledge that implementing the Draft CAP 2024-2029 is challenging but with the right resources and ambition a lot can be achieved. We wish the Council well in their endeavour in implementing Draft CAP 2024-2029. We hope the observations presented here are of benefit.

General Observations

Human Resources

It is welcomed that a Climate Team has been established but suspect that a larger team in needed particularly for Community engagement and to achieve targets.

Public Consultations

The Public Consultation in the Clondalkin Civic Offices was excellent. More consultations were needed and more embedded in the communities. Meeting people is the most effective way of communicating.

Action Tables

Assignment of Action Type – Adaptation/Mitigation or Other?

The primary objective of the Draft 2024-2029 CAP should be the reduction of GHGs i.e., mitigation. This can be achieved by promoting actions that reduce activities producing / resulting in GHG emissions e.g., reduction in petrol/diesel car use. But it can also be achieved through actions that remove GHGs e.g., planting of trees. It is important that actions are assigned appropriately as mitigation or adaptation or both.

There are some actions that are neither but fall under public awareness. Actions under public awareness only become mitigation or adaptation action IF it leads to such an action being taken.

For example, T5 under transport:

There are other actions that are infrastructure provision or maintenance. These also only become mitigation or adaptation IF they result is mitigation or adaptation action. For example, T6 under transport.

In these instances, it is important to categorise the action appropriately and to establish if resulting further actions are taken. This is the measure of the effectiveness of the initial action. For example, how does Maintain a high standard of active travel routes by  ensuring regular cleaning and annual maintenance to encourage ongoing use measured as Number of meters cleaned; Number of meters maintained  translate to a mitigation of GHG emissions, and how is that measured? How can the desired effect be encouraged?

This level of clarity is necessary, otherwise we may be fooling ourselves into thinking the objectives are meeting the desired outcome of a reduction in GHGs emissions.

Actions

Some of the actions are more less as per the previous plan. For example, 2019-2023 CAP, N12 is the same as the N6 in the current Draft CAP. This would suggest that there is carry over but some may be a continuation. Actions that are a carry over or are a continuation from the previous plan should be distinguished from new actions. A review or reflection of progress needs to be carried out periodically to identify what else can be done to achieve the actions set out.

Tracking Measures

Tracking Measures need to be measurable targets that lead to measurable outcomes of reduction in GHG  emissions. What are the target numbers /quantification for the tracking measures?

Evidence Based Climate Action

Figure 3.4 gives the GHG emissions for South Dublin based on data from 2018 and as a percentage.  Is there more recent data available?

Can the tonnes/quantity be presented to communicate the what this means in real terms? Proportions can mean very different things when it comes to quantity.

Data Presentation and Consistency

On page 63, it states “ In South Dublin, the  transportation sector is the largest contributor to GHG  emissions, with an estimated 42.5% of our total emissions.” Which is at odds with the 34% in Figure 3.4. The figures stated need to tally.

Energy and Buildings

Housing

Have the projections / forecast included the proposed increase in commercial and residential properties outlined in the 2022-2026 County Development Plan? Are they accounted for?

Social Housing Retrofits

 Seven years is a long time to complete the Social Housing Retrofits. How can the Council actively lobby the Government to provide the funding to accelerate this action in the first instance?

Data Centres and Renewable Energy

The text states on page 33 that “data centres in South Dublin responsible for 32% of emissions in the county” presumably based on 2018 data as per Figure 3.4. This a considerable proportion of the emissions and second only to transport at 32%?

 On page 34, Potential Strategic priorities for the wider South Dublin area based on the Dublin Region Energy Masterplan(23) include:

As of November 2022, 30 of the 70 data centres in Ireland were located in south Dublin (Irish Independent). The % of GHG attributed to Data Centres is probably higher given the data is from 2018.

How can the Council include actions that “ maximise renewable generation” such as retrofitting of existing Data Centres, and other high area commercial premises e.g.,  AMAZON distribution centre with solar panelling, heat capture, etc.? Actions are needed specific to Data Centres.

Flood Resilience

It would be of benefit to the public to list the minor work schemes mentioned on page 77. It would also benefit the Council as this could encourage local knowledge input. Additional actions to consider under flood resilience:

• Actively discouraging garden paving
• Promoting retrofitting of SuDS where gardens have been paved
• Use Rathcoole Park as a public demonstration for F9 and F10

Nature Based Solutions

Trees

All the actions relating to trees are to be welcomed. Trees are a key component and known carbon sink. We have established via estimation by a qualified third party that the Woodlands in Rathcoole sequester around 230 tonnes of CO2 per year, the equivalent of emissions from 50 cars.

Currently there is a deficit of native woodland and the Council has an opportunity to set aside Council lands to establish continuous cover native woodland, thus creating biodiversity opportunities. The Council is encouraged to  identify current SDCC owned lands with Woodland and manage for their preservation.

Nature Based Solutions Demonstration Projects

A simple action would be to provide simple demonstration projects to communicate to people what Nature Based Solutions and other climate actions look like.

Rathcoole Park and Woodlands would be a great public demonstration site for Flood Resilience, Nature based solutions to climate change, SuDS and development of further natural flood under F9, F10 and F15, and N7 and N9.

Plans and Policies

The Draft CAP lists three Plans supporting Nature Based Solutions:

• SDCC’s Green Infrastructure Strategy, outlined in the  County Development Plan 2022-2026
• The SDCC Biodiversity Action Plan 2020-2026,  ‘Connecting with Nature’,  and
• ‘Living with Trees’, South Dublin County Council’s  Tree Management Policy 2021-2026

The actions listed in the Draft CAP could be cross referenced with actions, in the above policies and plans for clarity, improved transparency, tracking and measuring. Better still, would be to integrate all the actions into a separate document/tracker.

Again, and this has been highlighted often, the Council needs to expand its view of hedgerows and woodland beyond Parks in its care to other lands that it owns, and to include the broader County. Action N6  is at odds with itself, with an action for hedgerows and woodlands in Urban areas on one hand and Parks on the other, yet has a tracking measure to quantify the carbon impact of the County’s trees.

The Council needs to have an evidence based quantification of the County’s Green Infrastructure, and draw on the expertise and assistance of other organisations in this sphere.

 It is acknowledged that the Council has moved in the right direction concerning Hedgerows, biodiversity and the Environment in their assessments of Planning Applications but more needs to be done.

Community Engagement

Communications

It is good to see that:

Progress in implementing climate actions under this plan will also be communicated via our Climate Action Website (www.southdublinclimate.ie).

Currently, it is not possible to easily find progress made in implementing the actions for the previous plan, presuming it is on the website.

The Draft CAP 2024-2029 also states:

“ The Council uses a range of communication tools, such as our Climate Change Newsletter and Climate Action Website (www.southdublinclimate.ie) to inform and educate on what we can all do to reduce our impact.”

With so many other demands on Council time, it can be a challenge to meet all targets but communication and provision of information is vital to keep on top of.

Website

It is easy to find Climate Change on the SDCC website. It is well laid out and very informative. While develop the Website is an action, reviewing /determining fit for purpose, and inviting feedback is always beneficial.

The website would benefit from adding more to the drop down menus across the different web pages to improve navigation. For instance, some “At Home” actions are listed but then “At Work” actions are not.

Additional Actions could be to:

• Provide links to the relevant SPC reports and Council presentations
• Hold Virtual Workshops/Information dissemination
• In person Road shows
• Expanding the mailing list
• Offer presentations to community groups

Make Internal Communications available:

•  Annual Implementation Plan

As a resident and worker in SDCC, and somebody with an passion for sustainability,  I welcome the comprehensive draft climate action plan and ambitious targets. In the following observations I will add some suggestions and ideas on how SDCC can be a leader in climate and biodiversity action.

SDCC currently run a scheme where residents can apply for an upgrade to their heating boilers. A relation of mine recently benefited from the scheme and got a new oil fired boiler. This relative was never given any information on heat pumps and did not know anything about them. This worthy scheme should give information and incentives for people to switch to heat pump technology.

T8 talks about bicycle parking. below are my observations as a cyclist and motorist.

Firstly I would like to thank you for some of the new cycling infrastructure that has been developed in recent years. The dodder cycle route is a fantastic addition to our county and I have also enjoyed the new cycle path along the n81 at Jobstown.

These have increased the appeal of recreational cycling and are key to promoting active travel going forward.

The cycle track from Tallaght Village to Balrothery is in my experience is a good example of a commuter cycle track and I use it regularly.

However, as someone who is a commuter cyclist and does most of his short trips (shopping, banking, Creche runs) by bike, I am writing to highlight some of the difficulties faced on a regular basis in and around Tallaght Village.

1. Greenhills Road

I live in Kilnamanagh and bring my son by bike to Creche in Tallaght Village each day. The route is only partially served by cycle paths with the following sections forcing cyclists onto the very tight traffic: 

- Tymon park to Astro Park Tallaght 

- entrance to Bancroft Park - junction Main Street 

On the return leg there are no protected cycle paths from:

- Junction Main Street to Bancroft Park

- Harvey Norman to Mayberry Road.

There is one particular part at the entrance to Harvey Norman where the bend forces the cyclist quickly out onto the busy traffic. This sharp bend needs plastic protective bollards as a matter of urgency.

Negotiating traffic like this is one thing when on my own but it’s a very scary prospect when I have my 2 year old son on the seat at the back.

2. Bicycle racks 

Tallaght village has an appalling provision of bike racks to safely lock a bike. I cycled around the main streets in Tallaght Village and counted the following in relation to Bicycle spaces Vs car spaces : 

- Main Street (Ulsterbank to the dragon Inn) then:

30 Car vs Bike 4 spaces

- Village green (AIB to leisureplex)

Car 11 vs Bike 0

- parking square at Molloy’s/Leisure plex 

Car 90 approx vs Bike 0

- new Bancroft square and pedestrian area (by Iceland) 

Car 0 v Bike 0

- Abberley square (Abberley hotel, Smyths Toys, etc)

Cars 150-200 approx vs Bikes 0

In fact in the whole of the central Tallaght Area I only found only 3 locations where a bike could be locked safely: BOI , SvdP opposite PTSB and Cash for Gold (main street).

The following important places have no bicycle racks outside and easily could have: 

- AIB, Ulster Bank, Spar, Molloy’s Bar, Costa Coffee (near Lidl), Macaris, Smyths Toys, Any takeaway places, Leisureplex, Abberley hotel and bar etc etc.

This forces cyclists into locking bikes to railings and traffic sign posts and can create problems for pedestrians.

Bearing in mind that the space needed for just one car can provide 5 racks for bicycles its hard to understand why there are not more. I'm sure SDCC have the accurate numbers for how many car parking spaces there are in the Tallaght central area but I estimate 400-500. Converting just 10% of them to bicycle racks could provide up to 250 bicycle racks.

Please note I saw two examples of spiral racks that a wheel can be locked to. These are not suitable for locking a bike as a wheel can be easily removed and the rest of the bike stolen.

3. Cycling and pedestrian space

It's very evident that Tallaght Village is dominated by cars. On most of Main Street there are effectively 3 lanes (Two for traffic and one for car parking). At least one of these lanes should be used for active travel. It would require creating a one way traffic system for cars (this could be easily achieved as there are suitable detours available), or even better still, full pedestrianisation of the public space. This would give a new lease of life to our village space and encourage footfall and help businesses.

This summer has shown us how Climate Change is having a devastating effect across the world. Business as usual is not an option and active travel is one key part of the solution. To get people onto bikes and walking we must create the infrastructure for them to do so safely. Tallaght Village is currently way behind and I would like to see an urgent response to this by SDCC.

N5 - Miyawaki Forests

Stepping stones forests have led in this space and should be made a formal partner of SDCC in the roll out of Miyawaki Forests

N12 - Useage of chemicals

SDCC should publically publish the number of Liters of glyphosate and other chemicals used each year and show the reduction over time.

T13 - Active travel schemes

SDCC should cost and consider gifting a bicycle to every child in the county at a certain stage of their schooling ie once a students enters 6th class they are gifted a bike or voucher to buy a bike. Adults benifit from the bike to work scheme, there should be a similiar scheme for children.

While the inclusion of a map of green corridors is extremely helpful, SDCC could perhaps raise more awareness about the importance of these ecological corridors, and of the role of private green gardens within these corridors.
Going forward planning permission should be a requirement, if it is proposed to remove a private grassed garden area, and replace it with concrete, paving, tarmacadam, or artificial grass lawn. This might help in raising awareness of the negative impact of soil sealing, etc.

Just recently over 150 to 200 mature and semi mature trees have been removed in the Clondalkin Clonburris SDZ (Seven Mills and the back of Ashwood Estate) area by SDCC or contractors working on its behalf. While it is understood that this is to facilitated much
needed housing in this area - It should be policy that for every tree that has to be removed three or more should be replanted.
There are large green public areas in Clondalkin that are devoid of trees. For example the areas adjacent to the R113 boundary Cherrywood Avenue and Clondalkin Leisure Centre and Moyle Park College, and the area between Alpine and Ashwood Estates and the boundary between these estates and the R113, and also along the banks of the Grand Canal.

To promote biodiversity and wildlife, the old hedgerow that is also between these two estates needs to be replanted as there are large gaps in parts. Some gaps are due to storm and bad weather damage over the years, and part of it was removed by SDCC for access to build the pedestrian and cycle path between the Bawnogue shopping centre, and the boundary of the R113. The public lighting alongside this pathway, should be wildlife friendly as Bats and Hedgehog have been observed alongside it and the hedgerow. The recommended one Metre grass nettle area each side of a hedgerow that should Not be cut, this rule should be strictly adhered to whenever grass-cutting is being carried out by SDCC or its agents.

The law states that it it is an offence to destroy vegetation on uncultivated land between the 1st of March and the 31st of August each year.

In general, untrimmed, thorny hedgerows containing shrubs such as blackthorn, whitethorn, holly, briars, ivy and brambles are favoured by birds as they provide food, shelter, nesting places and protection from predators during the breeding season. With regards to the law SDCC where complaint, when in February this year. They or their agents, unnecessarily cut or it could be described more correctly as, flayed vegetation similar to the above all along the Bawnogue Road. From the entrance at the junction with new Nangor Road, and ending near the Grand
Canal at the Lindisfarne and Ashwood Road estates. The correct time to do this type of work if its necessary should be in the month of September. As February is too near the breeding season, and as birds also need the shelter this vegetation provides in the winter months. SDCC should Consider proper cutting trimming instead of flaying, which may cause no regrowth in some vegetation. Regarding these observations SDCC should be proactive rather than reactive, and rather than the unnecessary cutting of vegetation. Their human and other resources could be diverted to other necessary maintenance tasks. For example replacing damaged trees and
fixing/straightening existing tree stakes or re-staking them.

SDCC should carry inspections to see if its necessary for public safety reasons to cut back vegetation growth over boundary fences onto roadways or cycle/ pedestrian pathways and to remove the fallen leaves especially in Autumn. A case in point is the cycle/pedestrian way on both sides of the R113 and between the junction into Dunawley Estate and the junction with Thomas Omar Way North Clondalkin, and from the start of Thomas Omar Way to Kisogue College. Also a lot of directional Signs are being obscured by overgrowth from trees or
shrubbery in all the areas that SDCC have responsibility for. Failure to do these necessary task could cause accidents and leave SDCC open to litigation.