Fingal Climate Action Plan Overview
You may be aware of the Draft Fingal Climate Action Plan 2024-2029 – below is a summary of its main points. We encourage everyone to have a look at the Fingal website, especially the other submissions already made, and to make their own submission before the deadline on Fri 3 November, 5 pm.
Summary of the Fingal Climate Action Plan
If the presentation does not display properly, please use the download link to access the PDF.
Thanks to committee member Miriam Sweeney for this overview!
We hope to make a submission in good time before the deadline (3 November 2023) so that others can see what our thinking is on this important plan.
*Update 27 October 2023: Our submission is now up. See it in full here.*
Sustainable Skerries welcomes the plan in principle but suggest better tracking and climate neutrality by 2040!
Comment on ‘Introduction’ to Draft Climate Action Plan:
All actions in the Climate Action Plan need to be linked to specific, measurable, achievable, relevant and time-bound goals.
Sustainable Skerries welcomes the dual vision of becoming climate neutral and climate resilient.
The ideal emphasis of a Climate Action Plan is on mitigation first, adaptation second, and avoiding climate-change-related problems in the first place. However, we recognise the need to include mitigation and adaptation actions in the plan. The AR6 Synthesis Report Climate Change 2023, from the Intergovernmental Panel on Climate Change (‘IPCC’) emphasises the importance of both mitigation and adaptation actions https://www.ipcc.ch/report/ar6/syr/resources/spm-headline-statements. Nonetheless, we would like to highlight the requirement to focus on both mitigation and adaptation equally. Adaptation actions should not detract from the need to continue to urgently focus on mitigation.
Obviously, there is only so much a county council can do, but the influence of setting an example in reducing carbon (and carbon-equivalent) emissions should not be underestimated. For that reason, we feel that being climate neutral by 2050 is too low a target (albeit in keeping with the Low Carbon Development (Amendment) Act 2021) and suggest changing that to 2040 at least. For instance, Waterford is aiming for that Carbon Neutral Waterford – Roadmap 2040 WEB.PDF (waterfordcouncil.ie), and Fingal should join them. We suggest following their example and putting more emphasis on the decarbonising zone.
Fingal could also learn from the experiences of Cork City, selected by the EU as one of 100 European cities leading on climate action and aiming to be carbon neutral by 2030! Zero Carbon Infrastructure – Cork City Council.
All actions in the Climate Action Plan need to be linked to specific, measurable, achievable, relevant and time-bound goals. Multiple actions are currently too vague with no targets specified, e.g., E10, E11, T1, T4 (none of which have targeted numbers or expected impact included). Actions must also be weighted in their impact so that a report on the progress can reflect in a quantifiable manner how much mitigation, or what progress with adaptation, has been made. We note that previous progress reports are insufficient in this regard as they only state whether an action is completed or not (with the majority being ongoing in any case, in which case it is impossible to assess progress without some indication of the impact of work done to date) FCC CCAP 2019-2024 Third Annual Progress Report.pdf (fingal.ie). Additionally, it is meaningless to report that “20% of all actions have progressed” if each action only moves the needle a tiny bit. Indeed, there is no indication across the multitude of actions in each of the six themes as to what actions take priority or are considered most impactful, again emphasising the need to carry out an impact assessment for each action e.g., in terms of emissions or energy efficiency. This should also help with prioritisation and informing where budgets are spent.
We propose that in addition to a “Tracking Measure” being captured in the summary action tables, a column is inserted for “Yearly target range”. We question how a Key Performance indicator can be assessed without a target range being set in advance, or how “Robust oversight and reporting” can be executed without a target-setting exercise in the first instance.
We note that Dublin Airport and the impact of air travel on greenhouse gas emissions are not mentioned at all (data centres at least are referred to) – should Fingal County Council not at least aim to use its influence to reduce the impact of the aviation sector?
Potential additional benefits and opportunities:
p.18 “By providing networks of natural wildlife corridors through the urban environment we will help animal and plant species migrate through the changing landscape.”
“Changing landscape” should be clearly defined here. It is important that the trade-offs in multi-use corridors (e.g., greenways) intended for climate, people and biodiversity are fully acknowledged and factored into site selection and design, as high disturbance levels will not deliver much benefit for biodiversity
Comment on ‘Climate Action Plan Process’:
Need to correct the oversight in omitting the North-West Irish cSPA
It seems that there has been an oversight in omitting the North-West Irish cSPA (site code 004236 North-west Irish Sea SPA | National Parks & Wildlife Service (npws.ie)) from the Appropriate Assessment Screening, this needs to be addressed – see the submission by Naul Community Council
Concern Draft Climate Action Plan is inconsistent with the Habitats Directive | Fingal County Council Online Consultation Portal.
Comment on ‘Baseline Emissions Inventory’:
Clarification of the data centre emissions data needed; Fingal emissions data later than 2018 would be helpful
P.29 of the draft plan states that “Data centres represent 13.1% of the commercial sector’s emissions”. It is not clear if this is 13.1% out of the 31% for the sector (i.e. 4.06% of the total for Fingal) or 13.1% of the total for Fingal. Please can you clarify which applies in the final version of the document. Irrespective of this, the impact is significant. There are currently no actions in Section 5 Energy and Buildings targeting this source of emissions. Actions should be added, such as engaging with the SEAI and large industrial users (including data centres) to discuss e.g., renewable energy or other solutions, attaching emissions-related conditions to planning permission applications etc. Such actions would be consistent with the government principles on data centre development, which include climate-change-related considerations New Statement on the Role of Data Centres in Ireland’s Enterprise Strategy published – DETE.
Additionally, it would be helpful to also include a more recent estimate of Fingal’s greenhouse gas emissions if possible, e.g. for 2022, so the public can understand the trend since 2018 and therefore the extent of the challenge ahead.
Finally, for this section, we acknowledge that this is a draft document, however, it has been made accessible to the public and regrettably, most of the figures on p.28 are not fully legible, as they appear to have been cut and pasted from the original reference material. It is important that all key figures, tables, graphs etc. are fully legible in the final document.
Comment on ‘Responding to Risks-Emergency Response Planning’:
A couple of open questions
This section of the plan is very high-level. Does the Council carry out scenario planning to detail how it would respond to different types of emergencies specific to Fingal? Does it carry out lessons-learned exercises following major incidents and use these to improve future responses?
Comment on ‘Energy and Buildings’:
Need for additional actions regarding SEAI / Industry. Kudos for leading by example with buildings under the control of FCC
We welcome the Council leading by example as evidenced by the large number of actions concerning the buildings it controls. As per the comment under “Baseline Emissions Inventory”, there are currently no actions targeting emissions reductions for large industrial energy users such as data centres. Actions should be added, such as engaging with the SEAI and large industrial users to discuss e.g., renewable energy or other solutions, attaching emissions-related conditions to planning permission applications etc
Comment on ‘Transport’:
Emphasis should be on avoidance first (helping active travel & public transport), move towards electric then – and what about air traffic?
The emphasis should be on reducing traffic first (by improving active and public transport), then on moving towards low-carbon / no-carbon transport.
One barrier to using bikes to get to the train station is the real danger of theft; individual bike boxes are too small for any non-standard bike and expensive to the user. An action could be added to introduce multi-bike parking facilities like the ones in use in Australia About Parkiteer – Parkiteer.
Given the increased likelihood of flooding (section 3 of the plan), actions on infrastructure developments for active travel should be considered in conjunction with actions on flood resilience, as these are interconnected. Actions F12 – F14 on surface water management and action F17 on sustainable drainage systems for new developments are important here. Active travel routes should incorporate “green infrastructure” features, such as trees, see A framework for assessing the quality of green infrastructure in the built environment in the UK – ScienceDirect.
We welcome actions T22 and T23 on shared mobility, specifically, we believe that community car sharing for electric cars should be explicitly mentioned here.
Ireland’s transport emissions continue to increase and there is an over-reliance on the increased use of electric vehicles to address this Transport | Environmental Protection Agency (epa.ie). In that context, it is disappointing that some measures are only suggested for 2026 or even 2028 (e.g., T14, T15, T34, T35.) For T35 on mitigating the impact of the Council’s own business travel, before considering carbon offsets we suggest prioritising a policy of reducing travel as much as possible e.g., meeting remotely rather than travelling (and particularly avoiding flights).
Comment on ‘Flood Resilience’:
Need for cooperation between the OPW and the Fingal Biodiversity Team re F5: Flood Alleviation Schemes especially Mill Stream Skerries
“F5: Progress Flood Alleviation schemes in conjunction with the OPW – including Mill Stream Skerries, Bissett Strand and The Green Malahide Village, Portmarnock Bridge,”
Ongoing ecological studies of the Mill stream area, Skerries, point to the potential for natural flood risk management, incorporating existing wetlands, in this small catchment. It is important that OPW engage with the Fingal Biodiversity Team to deliver such an ecologically sensitive scheme. An Ecological report on the Skerries Millstream area is due shortly from the Fingal Biodiversity team. We would ask that this engagement is carried out as soon as possible, and not deferred until 2029+ as documented. This is particularly urgent considering the recent flooding in this area.
Comment on ‘Nature-Based Solutions’:
Some detailed comments regarding specific measures.
p.74 – the important role of tree planting and ecosystem restoration in sequestering carbon over the long-term, given the appropriate species and climate conditions, should also be emphasised here, see Summary for Policymakers — Special Report on Climate Change and Land (ipcc.ch).
“N2: Map and survey all significant/historic stands of woodland within the county e.g. in excess of 5ha, and review the effectiveness of the protection offered under the Green Infrastructure Network Zoning of woodlands in the County Development Plan”
Given the lack of woodland in Fingal, and its fragmented nature, limiting this study to woodlands of more than 5ha would likely miss important small woods that have the potential to be restored and expanded.
“N6: Explore funding models for carbon offsetting to fund wetland and woodland development”
It would also be prudent, as part of this study, to explore funding/legal arrangements for biodiversity offsets, to facilitate the achievement of biodiversity net gain for more developments.
“N7 – Commission a study to report on the ecosystem services/nature-based solutions provided by Fingal’s trees with reference to their economic/climate change adaptation benefits”
As the ecosystem services (benefits to humans) of trees in both urban and rural environments are well researched, it is suggested that this study focuses on identifying areas in Fingal where tree planting/natural regeneration may be best targeted to provide optimal ecosystem services.
“N9 – Initiate a programme of targeted Strategic Annual Tree Planting including identifying and mapping priority locations, to include sites suitable for woodland creation. Reviewed in an annual works programme, presenting what is planned for the coming year. Taking advantage of government funding programmes such as the New Woodland Creation Scheme on Public Lands”
Identifying locations suitable to encourage the natural regeneration of woodlands should be included in the mapping study. Areas particularly suitable for woodland creation on private lands e.g., adjacent to potential seed sources, along river corridors or in areas with former woodland cover, could also be identified, and an information campaign implemented to inform the public of relevant private government funding schemes such as the new Native Tree Area Scheme, for which no licence is required.
“N10 Prepare a list of suitable tree species recommended for differing situations/functions and make available to developers and other stakeholders following the Guiding Principle of ‘right tree in the right place’”
The guiding principle also includes ‘the right management’ and therefore suitable management regimes for different situations/functions need to be specified as part of this exercise, particularly where the aim is to create a woodland ecosystem. Advice for developers/stakeholders on planting approaches that best avoid tree vandalism would also be helpful.
Actions N11-N15: Preservation and Conservation
The council are to be commended on Actions N11 to N14, particularly regarding the planned implementation of restoration projects. More specific and ambitious targets for Action N15 should be set.
Actions N17 – N18: Agricultural Sector
These actions appear to be straightforward and should be accelerated sooner than the current timeframe of 2028.
Comment on ‘Circular Economy and Resource Management’:
Fingal leading by example is good – food waste prevention should be added to waste segregation; Bring Bank network needs to be extended asap
It is positive to see the Council intending to lead by example through Green Public Procurement actions to reduce its own waste, and land use management.
The food waste actions (R11 and R12) focus on waste segregation, we encourage the Council to add actions on food waste prevention, such as encouraging local businesses to partner with FoodCloud FoodCloud: Food waste hurts our planet and/or use food waste prevention apps (see recent news article https://www.independent.ie/life/family/i-used-an-app-to-prevent-food-waste-and-saved-49-on-my-shopping-bill-in-four-days/a165190747.html#:~:text=The%20Too%20Good%20To%20Go,of%20food%20waste%20in%202015 ).
R18 – expanding the Bring Bank network
We are happy to see this action included. We propose the following additional actions to help empower people to affect change in this area: additional civic amenity sites, the provision/expansion of community repair and recycle spaces in our towns and villages, and the provision/expansion of deposit and return scheme facilities.
R17 – extending opening hours in Coolmine in line with the Estuary Recycle Centre
It would be helpful to also extend the opening hours of both centres to include Sundays. For many people, the weekends are the best time to visit a recycling centre and limiting the opening hours to Saturday only is restrictive. As above, we also believe that additional Civic Amenity Sites are necessary given Fingal’s size and population.
Comment on ‘Community Engagement’:
Education and awareness are necessary but not sufficient – infrastructure and facilities need improvement too
Sustainable Skerries welcomes the Council’s new inclusion and recognition of the importance of community engagement and supports all actions included here (whilst noting that some of them could be more specific and require explicit targets – see comments under the Introduction and Implementation sections). We also welcome the appointment of a Fingal Community Climate Action officer, to guide and support communities in developing projects and initiatives and the opportunity to avail of funding through Strand 1 of the “Building low carbon communities” Community Climate Action Fund.
We note that the actions here focus on education and awareness. These are necessary but not sufficient for action, people also need to have the facilities/infrastructure to be empowered to affect change. Citizen empowerment is a key theme in Ireland’s Climate Action Plan 2023
https://www.gov.ie/en/publication/7bd8c-climate-action-plan-2023/. More empowerment actions should be included in the plan. For example, we have proposed additional actions under the “Circular Economy and Resource Management” theme, such as the provision/expansion of community repair and recycling spaces, to enable behavioural change.
Comment on ‘Decarbonising Zone’:
Let us learn in real time from the pilot!
Sustainable Skerries looks forward to learning from this pilot.
We request that regular updates on progress and learnings be made publicly available.
Comment on ‘Implementing and Reporting’:
Funding / resourcing, reporting & tracking and embedding the environmental principles in all of the Council’s work is a must!
Firstly, all actions must be appropriately funded and resourced. It is not clear from p.123 of the draft plan whether this is the case, although the mentioned expansion of the Council’s core Climate Action team and references to government and European funding opportunities are positive. We urge the Council to ensure that all necessary funding is obtained, ring-fenced, sufficient staff are in place and highest impact actions are prioritised, to support and deliver on the plan.
Secondly, we believe that transparent tracking and monitoring of progress against the agreed actions is critical. We welcome the reporting outlined on p.124 of the draft plan and the inclusion of tracking measures in the tables of actions in Section 5. However, the measurement of actions alone is insufficient. As per the comments under the Introduction, multiple actions are currently too vague with no targets or expected impact specified. For such actions, targets need to be set and the expected impact assessed. e.g., E30 how many/what proportion of SMEs availing of SEAI funding would be considered a good outcome, what will this achieve in terms of emission reductions? T1 How many additional metres of high-quality walkways is the Council targeting, with what expected reduction in short car journeys? T13 How many traffic calming measures is the Council targeting with what expected impact? etc. Specifying targets or targeted ranges for the tracking measures would enable “red/amber/green” traffic light-type status reporting to be developed for each action to indicate whether an ongoing action is on track vs its target or requires remedial action (e.g., green to indicate on-track, amber at-risk, red significant issues). As previously stated, actions must also be weighted in their impact so that progress reporting can reflect in a quantifiable manner how much mitigation, or what progress with adaptation, has been made. Reporting the % of actions progressed is not meaningful without an assessment of their impact vs target. We propose that in addition to a “Tracking Measure” being captured in the summary action tables, a column is inserted for “Yearly target range”. We question how a Key Performance indicator can be assessed without a target range being set in advance, or how “Robust oversight and reporting” can be executed without a target-setting exercise in the first instance.
Thirdly, we strongly support the environmental principles in Table 7.1 of the plan. We believe that such principles should be embedded into all the Council’s work, not just in the context of the actions in the draft Climate Action Plan. Otherwise, there is a risk that work undertaken outside of the context of this plan could undermine climate action.
Strategic Environmental Assessment Report:
Supporting the environmental principles and the incorporation of the recommendations of this report
As previously stated, we strongly support the environmental principles in Table 7.1 of the plan and the incorporation of the recommendations from this report.
Appropriate Assessment- Natura Impact Report:
Need for rectifying oversight in omitting the North-West Irish cSPA
It seems that there has been an oversight in omitting the North-West Irish cSPA (site code 004236 North-west Irish Sea SPA | National Parks & Wildlife Service (npws.ie)) from the Appropriate Assessment Screening, this needs to be addressed – see the submission by Naul Community Council
Concern Draft Climate Action Plan is inconsistent with the Habitats Directive | Fingal County Council Online Consultation Portal.
Other comments on Fingal County Council Draft Climate Action Plan: Improvements regarding the Executive Summary suggested
The Executive Summary should set out the plan’s Vision, Mission, Goals and Targets in that order. Goals can be broad statements, whereas targets are more specific e.g., the 17 Sustainable Development Goals are high-level statements, with 169 specific targets associated with them. We believe that of the four “targets” on p.6, the first two are targets, whereas the last two are goals. These should be separated. Additional specific targets could be added, such as “Supporting a 51% (or higher) reduction in Fingal’s overall greenhouse gas emissions by 2030 relative to a 2018 baseline”, and “Reduce the costs of extreme weather events for Fingal by x% over 2024 – 2029 relative to a 2023 baseline” (or similar). It is important that targets refer to the baseline year where applicable, e.g., “51% reduction in the Council’s greenhouse gas emissions by 2030 relative to a 2018 baseline”.
Sustainable Skerries 
On slide 5 I find 1.4% of emissions being from agriculture hard to believe. Nationally it is 38.4% https://www.epa.ie/our-services/monitoring–assessment/climate-change/ghg/latest-emissions-data/