Re. Local Authority Climate Action Plan 2024-2029 and associated SEA Environmental Report
Dear Sir / Madam,
We acknowledge your notice in relation to the Local Authority Climate Action Plan 2024-2029 (‘the Plan’).
The EPA is one of the statutory environmental authorities under the SEA Regulations. In our role as an SEA environmental authority, we focus on promoting the full and transparent integration of the findings of the Environmental Assessment into the Plan and advocating that the key environmental challenges for Ireland are addressed as relevant and appropriate to the plan. Our functions as an SEA environmental authority do not include approving or enforcing SEAs or plans.
Where we provide specific comments on plans and programmes, our comments will focus on the EPA's remit and areas of expertise (in particular water, air, climate change, waste, resource efficiency, noise, radon and the inter-relationships between these and other relevant topics e.g. biodiversity), as appropriate and relevant to the particular plan or programme.
This submission highlights several key environmental issues to consider in preparing the Plan and SEA. Some key comments and recommendations are provided below in relation to the Plan. Appendix I includes comments to consider in the SEA Environmental report. Additionally, our previous submission, made at the SEA Scoping stage of the process, should also be considered at this time.
EPA Comments and Recommendations
Full and early implementation of ambitious policies and measures supported by legislation are needed to deliver Ireland’s current and future commitments to be a climate neutral economy and climate resilient society by 2050. The development of carbon budgets, climate action plans, and the long-term strategies will be key to delivering this, provided that the necessary structures are put in place to ensure full implementation.

The Plan sets out a framework of climate actions to be carried out by the Local Authority, in collaboration with other key stakeholders, over the five-year period from 2024 to 2029. It represents a key element linking national and international policy commitments with climate action within the local authority area at a community and local level. We recognise that local authorities will set their own targets to achieve the 50% improvements in energy efficiency, under the Climate Action Plan, as well as the 51% reduction in Greenhouse gas emissions set out in the Climate Action and Low Carbon Development (Amendment) Act 2021.
We acknowledge the preparation of the Plan, which aligns with national climate change policy commitments, and which sets out actions to be taken by Local Authority, in collaboration with other key stakeholders, over the next five years.
Local Authorities need to ensure that there are sufficient suitable monitoring networks (that are maintained and producing high quality data at an appropriate resolution and frequency, to allow decision makers to make decisions on how to adapt. This could be flood defence related, making arrangements with respect to water resources, bathing water or issuing health warnings relating to hot weather, air particulates etc.
Climate adaptation involves being able to make decisions when the climate effects are magnified. Local Authorities have a direct role in this with respect to water and air. Consider including a commitment to ensure that monitoring arrangements remain fit for purpose, such that that the data generated from monitoring, can be used by decision makers such as Local Authority emergency planning teams or Met Éireann flood forecasting teams. This could also be applicable to any future drought forecasting teams or for air pollution forecasting teams.
Related to this, the monitoring data gathered provides validation of the climate change modelled projections, allowing future planning to bolster flood defence or have more adaptive water supplies in response to climate change.
You should also consider taking into account the EPA’s ‘Climate Change in the Irish Mind’ project in finalising the Plan. This research is part of the National Dialogue on Climate Action.
We suggest that the Plan include a specific action to carry out “implementation monitoring” to ensure that progress achieving the actions and measures across the Plan is being monitored and reported on.
The SEA should also assist in identifying ways to maximise the potential co-benefits of climate-related measures for air quality, human health, biodiversity, water quality and other interrelated areas (i.e. win-win solutions).

We recommend that the findings of the SEA ER and NIS are fully reflected in the Plan, to ensure that the relevant recommendations are fully considered and integrated as appropriate.
Environmental Authorities
Under the SEA Regulations, you should consult with:
• Environmental Protection Agency;
• Minister for Housing, Local Government and Heritage;
• Minister for Environment, Climate and Communications;
• Minister for Agriculture, Food and the Marine.
If you have any queries or need further information in relation to this submission, please contact me directly at c.omahony@epa.ie. I would be grateful if you could send an email confirming receipt of this submission to: sea@epa.ie.
Yours Sincerely,
______________________
Cian O’Mahony
SEA Section
Office of Radiation Protection and Environmental Monitoring
Environmental Protection Agency

Appendix I – Comments on the Environmental Report
Non-Technical Summary
You should ensure that the Non Technical Summary includes the relevant information as required under Schedule 2 of S.I No. 434 0f 2004, as amended.
Relationship with other plans and programmes
We acknowledge that the Plan has been prepared taking account of the key National plans including the National Climate Action Plan 2023. We also acknowledge that the Plan sets out the key plans, programmes and policies considered in preparing the SEA.
The Plan should include a commitment to remain aligned with high level plans and programmes, Guidelines, and legislation over its lifetime. The Climate Action Plan 2024 is currently being prepared and work will be commencing on the review of the National Planning Framework and Regional Spatial and Economic Strategies also. Any relevant updates of these plans/strategies should be integrated as appropriate into the Plan as relevant and appropriate.
The Plan should include a commitment to consider any relevant updated actions, measures or recommendations that may arise in updates to the National Climate Action Plan (or the National Planning Framework) over the lifetime of the Plan.
Strategic Environmental Objectives
We recommend that in considering strategic environmental objectives, they should where possible reflect the plan being prepared, rather than use more generic environmental objectives. This will help both in considering more specific monitoring and mitigation measures, when required.
Alternatives
We note the alternatives considered in the SEA and acknowledge the preferred option selected.
Mitigation Measures
Where the potential for likely significant effects has been identified, you should provide appropriate mitigation measures to avoid or minimise these. You should also ensure that the Plan includes clear commitments to implement the relevant mitigation measures.
Monitoring, Implementation & Reporting
The Monitoring Programme should be flexible to take account of specific environmental issues and unforeseen adverse impacts should they arise. It should consider and deal with the possibility of cumulative effects. Monitoring of both positive and negative effects should be considered. The monitoring programme should set out the various data sources, monitoring frequencies and responsibilities.
If the monitoring identifies adverse impacts during the implementation of the Plan, the you should ensure that suitable and effective remedial action is taken.

Guidance on SEA-related monitoring is available on the EPA website at https://www.epa.ie/publications/monitoring--assessment/assessment/strategic-environmental-assessment/06695-EPA-SEA-Statements-and-Monitoring-Report.pdf
EPA State of the Environment Report
Our State of Environment Report, Ireland’s Environment - An Integrated Assessment 2020 (SOER2020) identifies thirteen ‘Key Messages for Ireland’. Delivering Ireland’s long-term sustainable development and environmental objectives will involve many different stakeholders to address these key actions. The report recognises the need for full implementation of existing environmental legislation and review of governance/coordination on environmental protection across public bodies.
The EPA are currently preparing the next iteration of the SOER report, which will be published in 2024. We recommend that a commitment is made in the Plan, to take account of any relevant recommendations in the SOER 2024 report, once published, in implementing the Plan over its lifetime.
SEA Statement – “Information on the Decision”
Once the Plan is adopted, you should prepare an SEA Statement that summarises:
• How environmental considerations have been integrated into the Plan;
• How the Environmental Report, submissions, observations and consultations have been taken into account during the preparation of the Plan;
• The reasons for choosing the Plan adopted in the light of other reasonable alternatives dealt with; and,
• The measures decided upon to monitor the significant environmental effects of implementation of the Plan.
You should send a copy of the SEA Statement with the above information to any environmental authority consulted during the SEA process.
Future Amendments to the Plan
You should screen any future amendments to the Plan for likely significant effects, using the same method of assessment applied in the “environmental assessment” of the Plan