The Environmental Health Service (EHS) has drafted this submission to support South Dublin County Council (SDCC) deliver a Climate Action Plan for South Dublin that protects and promotes population health. It is set against the backdrop of the Healthy Ireland Framework

“where everyone can enjoy physical and mental health wellbeing to the their full potential, where wellbeing is valued and supported at every level of society and is everyone’s responsibility”

The observations are structured starting with some general statements on climate change, health and the Sustainable Development Goals (SDGs) followed by more specific observations in line with the layout/structure of the plan.

In the context of SDG 3 – Health for All of All Ages the EHS wishes to stress the importance of finalising a Climate Action Plan that is inclusive and leaves no one behind. The plan should be Age Friendly for older and younger persons, delivers for persons with a disability by ensuring people are not impaired or excluded from active participation in their community, delivers for youth/adolescents, delivers for disadvantaged and marginalised groups, delivers for the future ethnic and cultural mix in Dublin City and delivers for all genders, men, women, boys and girls.

Overarching Comments

The first part of the plans sets the scene covering the Executive Summary, Overview of South Dublin, the SDCC vision, an introduction, the climate action plan process an emissions profile for South Dublin and the Climate Change Risk Assessment for South Dublin.

The Vision articulated is “working together to ensure that South Dublin is a place with a strong focus on local living, sustainable mobility and quality of life for all, with leadership and initiative from SDCC to develop a low carbon and climate resilient county by 2050.

The EHS suggests a vision that goes beyond quality of life and places stronger emphasis on protecting and promoting health and well-being in the context of climate change to help deliver the vision of a Healthy Ireland.

Four key targets are set for the plan namely

50% improvement in the Council’s energy efficiency by 2030
51% reduction the Council’s greenhouse gas (GHG) emissions by 2030
To make Dublin a climate resilient region, by reducing the impacts of future climate- related events; and
To actively engage and inform our communities on climate action.

The EHS suggests that target 3 seeks to make Dublin a region resilient to climate threats that affect health but also seeks to deliver on the opportunities for health gain presented by climate action. For example more active travel should deliver healthier people in terms of addressing physical inactivity and cleaner air.

The EHS suggests target 4 go beyond engaging and informing our communities on climate action but seek to effect behaviour change and enable for example to make the healthy choice for people the easy choice. In the context of the latest Climate Action Plan for 2023 this may refer to the delivery of “Climate Literacy”.

The introduction section is particularly good with excellent graphics on for example the climate policy context and the actions that fall under Mitigation, Adaptation and those that fall into both categories. The key action areas to deliver on the four targets are also presented here in the introduction and are listed as

Energy and Buildings
Transport
Flood Resilience
Nature Based Solutions
Circular Economy and Resource Management
Community Engagement

As an action area Flood Resilience seems too narrow when one views the range of existing and future hazards faced in South Dublin. Perhaps a phrase along the line of Disaster Risk Management would better capture the range of hazards from extreme weather to slow onsets events illustrated in Fig 1.2 on page 11.

The potential added benefits of climate action are listed very well on page 20 which captures some of the opportunities for health gain under the Health and Well-Being part of Fig. 1.6.

The EHS suggest the list of co-benefits for health could be substantially expanded. Just one example might be how climate action can help deliver more sustainable diets for the citizens of South Dublin through the promotion of allotments/community gardens.

The climate action plan process is well explained setting out the principles of being ambitious, action-focused, evidence-based, participative and transparent. It’s not clear if state agencies with responsibility for public health were consulted or participated in the development of the draft plan.

The EHS suggests a list of agencies who participated or were consulted in the development of the plan is included as an appendix to the final plan.

The emissions profile data for SDCC itself and emissions within the county makes for very interesting reading. One question to ask is if the council needs to include emissions from staff getting to and from work in its profile? The same question applies to suppliers and sub- contractors used by SDCC? In the context of emissions in the county clearly the biggest sources of emissions are the commercial/data centre sector (46%), the transport sector (34%) and the residential sector (17%). The strategic priorities lists a number of different ways in which emissions in these areas are to be addressed.

The EHS recommends that indirect or scope 2 and 3 emissions be considered in the emissions profile for SDCC and actions include ways to reduce those emissions.

Blended working arrangements for some staff is an example of a potential solution in this area.

The EHS recommends that the need for cooling in summertime should be included in assessing energy demand for the three biggest emission sectors in South Dublin.

General Comment on Climate Change, Health and the Sustainable Development Goals.

Climate Change is the greatest threat to global health this century and climate action is the greatest opportunity for delivering health gain. Climate action includes activities Mitigate/reduce/eliminate Green House Gas emissions and Adapt to climate change in order to protect present and future generations.

The plan should support actions that move Ireland to “a low carbon, climate-resilient, and environmentally sustainable economy by 2050” as set out in the Climate Action and Low Carbon Development Act 2015 – 2021. The latest Government Climate Action Plan 2023 should form the basis for developing a low carbon, climate-resilient, and environmentally sustainable South Dublin by 2050 with interim targets for 2030. Examples of actions include

Citizen engagement – a plan that contributes to delivering “climate literacy” and enables citizens to take action to improve the quality of life for themselves and fellow citizens.
A plan that supports a just transition to a Climate Neutral Ireland and leaves no one behind.
A plan that builds better, to Zero Emission Building (ZEB) standard in all new construction and supports retro-fitting of all other building stock.
A plan that delivers healthier housing, healthier workplaces and healthier communities through effective urban planning, design and construction. In other words Healthy Place making
Development of a transport system that delivers on the principles of Shift – Avoid – Improve.
- A plan that through land use planning assists people to Reduce or Avoid the need for travel
- A plan that enables people Shift to more environmentally friendly modes of transport such as walking, cycling or public transport.
- A plan that Improves the energy efficiency of vehicle technology – for example perhaps only allowing car share that utilises hybrid or fully electric vehicles.
A plan that facilitates the large scale deployment of renewable energy technologies to help deliver Ireland’s emission reduction targets. This should include the utilisation of public buildings for the generation of solar power.
A plan that adapts to climate change and builds resilience for the residents of South Dublin. In practical terms this implies
- A community that is resilient to severe weather events such as floods, windstorms, extreme heat and other potential severe weather hazards.
- Incorporating rain water harvesting to build resilience to dry spells/drought conditions.
- Particular attention is drawn to protecting vulnerable people such as older persons and young children from extreme heat events and planning a landscape that limits the urban heat island effect, provides green and blues spaces, provides shade and other measures to cool the local environment in advance of and during heatwave events.
- A plan where drainage and waste management infrastructure limit the opportunities for vectors of disease to breed.
- Land use management that reduces exposure to aero-allergens that may contribute to the burden of asthma and other allergic impacts on people.

The plan should support action towards the achievement of the Sustainable Development Goals as set out in Agenda 2030. Specifically it should deliver towards SDG 3, which is to

“ensure healthy lives and promote well-being for all at all ages”. The achievement of SDG 3 is dependent on achieving so many other SDGs and the plan should map out the SDGs that will make the greatest contribution to SDG 3. One of the most relevant is SDG 11 “sustainable cities and communities”

South Dublin County Council Draft Climate Action Plan 2024-2029 - Submissions

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