The following is the long form of our submission; the actual submission, as uploaded on 17/08/2026, can be accessed here: Sustainable Skerries CAP26 Submission

Sustainable Skerries, a committee of the Skerries Community Association based in North County Dublin, welcomes the opportunity to respond to the public consultation on the next update to Ireland’s Climate Action Plan.

The context for Climate Action Plan 2026 is stark. The EPA’s May 2026 projections indicate that, even with full implementation of currently planned policies and measures, Ireland would achieve only about a 25% reduction in greenhouse gas emissions by 2030, against a legally binding national target of 51%. The second carbon budget for 2026–2030 is projected to be exceeded by between 53 and 82 Mt CO₂eq.

At the same time, the effects of a changing climate are becoming increasingly difficult to consider in the abstract. Met Éireann reports that July 2026 was Ireland’s second-hottest July since 1900 and the driest July on record, with rainfall nationally at just 17% of the 1991–2020 average.

We therefore agree that CAP26 must focus strongly on implementation and on the actions capable of having the greatest impact. In particular, we believe six overarching principles should guide the Plan:

1. Ireland must prioritise high-impact structural change. CAP26 should distinguish clearly between actions capable of materially reducing national emissions and worthwhile supporting activities whose primary benefits are awareness, biodiversity, adaptation or community resilience.
2. Agricultural policy must move beyond improving the greenhouse-gas efficiency of existing production towards diversification and land-use change. The State should provide much greater support for horticulture, tillage, organic farming, agroforestry and other forms of ecologically beneficial food production, while ensuring a fair transition for farmers currently dependent on livestock production.
3. Climate adaptation must become a design requirement now. Housing, infrastructure and spatial planning must be based on the climate Ireland is likely to experience during their lifetime, including increased risks from drought, water scarcity, intense rainfall, flooding, overheating and coastal impacts.
4. Energy and material demands matter as well as supply. Renewable energy must expand rapidly, but CAP26 should also constrain avoidable growth in energy and material consumption, particularly where large new energy loads could undermine decarbonisation elsewhere.
5. Transport policy should reduce car dependency in general, not merely fossil-fuel-car dependency. Spatial planning that reduces the need to travel, strong local services, public transport and active travel should come first, with EVs forming part of the solution for the motorised journeys that remain.
6. Climate action and biodiversity protection must not be traded against each other. Renewable energy development needs to be accelerated through strategic spatial planning, grid investment and more efficient procedures, while retaining strong ecological safeguards.

Delivery and accountability must underpin all six priorities. Given the scale of the projected gap to Ireland’s legally binding climate targets, Ireland’s problem is no longer a shortage of worthwhile aspirations. CAP26 must ensure that the changes needed actually happen.

Delivery, measurement and local implementation

Many of the points raised in our previous submission to the consultation on Climate Action Plan 2024 remain relevant.

Actions in local authority climate action plans should be linked wherever possible to specific, measurable, achievable, relevant and time-bound goals. We welcome the progress Fingal County Council has made to date, as outlined in its Climate Action Plan Progress Report of May 2026. However, where measurable targets are absent, it can be difficult to assess the scale of the impact achieved.

Local authorities need effective ways of determining which actions are having the greatest mitigation or adaptation impact so that limited funding, staff time and community effort can be directed accordingly. Reporting that an action has commenced or progressed is not, on its own, sufficient to demonstrate climate impact.

This does not mean that activities primarily supporting climate literacy, biodiversity, community resilience or engagement are not valuable. They can be extremely worthwhile. However, they should be identified and evaluated according to the outcomes they are intended to achieve rather than treated as equivalent to actions capable of substantially reducing greenhouse gas emissions.

Electricity demand, renewable energy and data centres

We remain concerned about the impact of rapidly growing data centre electricity demand. The Climate Change Advisory Council reported in 2026 that data centre electricity demand had grown from approximately 5% of electricity demand in 2015 to more than 20%.

As highlighted in the Oireachtas Report on Barriers to Achieving Climate Targets 2026–30, CAP26 should prioritise immediate and long-term electricity demand-management strategies, particularly in respect of very large energy users. 

The underlying principle should be that Ireland cannot rely solely on continually increasing renewable electricity generation while allowing avoidable electricity demand to grow without constraint. Increased electricity demand arising from necessary electrification of heating, transport and other fossil-fuel uses is different from discretionary additional demand from new large energy users.

New large energy users should therefore be required to demonstrate that their demand can be accommodated without jeopardising Ireland’s carbon budgets, security of supply, grid resilience or the decarbonisation of existing electricity demand. Where renewable generation is required to support new developments, this should represent genuinely additional renewable capacity rather than simply competing for renewable electricity already needed to decarbonise the existing economy.

We also remain concerned about evidence that increasing data centre electricity demand may contribute to energy affordability pressures for households and communities. 

See also Friends of the Earth Cost of Data Centre Growth in Ireland

Aviation

We ask that decarbonisation of the aviation sector is addressed more fully in CAP26. Technological improvements and alternative fuels should form part of the response, but CAP26 should also consider demand-management measures rather than assuming that continued growth in aviation demand can be reconciled with Ireland’s carbon budgets solely through future technological change.

Community engagement and public support

Community engagement is necessary for climate action but is not sufficient. People also need appropriate infrastructure, services and practical opportunities to change their behaviour.

CAP26 should therefore explicitly recognise that responsibility cannot simply be transferred to individuals and communities without enabling conditions. Local authorities and community organisations need adequate financial, technical and administrative support.

Our experience in Skerries suggests, for example, that retrofitting community buildings can be unnecessarily difficult. CAP26 should include measures to identify and remove the practical, regulatory and financial obstacles facing community organisations seeking to retrofit buildings or undertake other substantial climate projects.

There is also a need to understand better why climate measures that enjoy broad support in principle can encounter strong opposition when particular projects are proposed.

Recent examples in Skerries include debate around the proposed North Irish Sea Array offshore wind development and Fingal County Council’s Active Travel Plan.
Residents raise concern as Ireland’s six new offshore wind farms move closer to reality and regarding Fingal County Council’s Active Travel Plan Over 600 submissions made to Fingal County Council over Skerries Active Travel Plan | Irish Independent.
These are very different projects, and objections should not automatically be interpreted as opposition to climate action. Concerns may arise from genuine environmental or biodiversity issues, perceived financial or practical impacts, lack of trust or participation, disagreement about particular designs, or misinformation about climate change.

CAP26 should prioritise research into such experiences and systematically share lessons about early public participation, communication, decision-making and conflict resolution. Ireland needs to become better at distinguishing legitimate concerns that should influence project design from barriers that can be overcome through better information, consultation or support.

Climate-resilient buildings and infrastructure

It is generally easier and more cost-effective to incorporate climate mitigation and adaptation measures at the beginning of a development than to retrofit them later.

Buildings constructed in 2026 may still be in use towards the end of this century. Building regulations and planning requirements should therefore be based not only on present conditions but on the climate those buildings are likely to experience throughout their lifetime.

CAP26 should prioritise the development and strengthening of legislation and building standards covering measures such as:

• renewable energy generation and low-carbon heating;
• high levels of energy efficiency;
• water efficiency;
• rainwater harvesting and storage;
• greywater reuse where appropriate;
• sustainable drainage and management of intense rainfall;
• resilience to flooding;
• passive protection against overheating;
• resilience to extreme weather; and
• appropriate provision for EV charging.

The Climate Change Advisory Council has similarly highlighted the need for greater flood protection, improved water-use efficiency, indoor thermal regulation and greater resilience to extreme wind.

Climate adaptation should no longer be treated mainly as something to be added to existing buildings and infrastructure after problems arise. It should become a fundamental requirement of new development.

Transport and spatial planning

Transport remains Fingal’s second-largest source of emissions. However, transport policy should not focus primarily on replacing internal-combustion-engine cars with electric cars.

CAP26 should prioritise a hierarchy of reducing the need for motorised journeys; shifting journeys towards walking, cycling and public transport; and electrifying the motorised transport that remains.

Land-use and transport planning should therefore increasingly make it possible for people to live close to employment, schools, shops, services and amenities. Compact, walkable towns and neighbourhoods with strong local services can reduce car dependency while also improving quality of life.

Towns such as Skerries also need substantially better local public transport. More frequent local bus services, ideally using zero-emission vehicles, could reduce car dependence without many of the long infrastructure lead times associated with larger transport projects. There is local support for improved services of this kind.

As highlighted in the Oireachtas Report on Barriers to Achieving Climate Targets, measures such as additional EV bus stock, school bus provision and rural bus networks can be frontloaded without the infrastructural delays affecting major transport projects, and should therefore be prioritised.

CAP26 should therefore place greater emphasis not simply on the number of EVs on Irish roads but on measurable reductions in car dependency, private vehicle kilometres and the proportion of everyday journeys that require an individual motorised vehicle.

Renewable energy and biodiversity

Ireland urgently needs much more renewable electricity and the grid infrastructure required to use it effectively. Planning and delivery processes need to become faster and more predictable.

However, climate action and biodiversity protection should not be treated as competing objectives. Poorly located renewable-energy infrastructure can create genuine environmental impacts, while lengthy and adversarial project-by-project disputes also jeopardise Ireland’s ability to meet its renewable-energy targets.

CAP26 should therefore support stronger strategic spatial planning for renewable energy, identifying suitable and environmentally sensitive areas at an early stage, supported by robust ecological evidence and meaningful community participation.

This should enable Ireland both to accelerate renewable-energy deployment and to uphold strong environmental and biodiversity obligations.

Land use, housing and climate resilience

We recognise the urgent need for additional housing. However, meeting housing need should not mean that climate adaptation, food security, biodiversity and flood resilience are given insufficient weight in planning decisions.

CAP26 should promote a clear hierarchy that prioritises the development of existing serviced and residentially zoned land, brownfield and infill sites, vacant and underused buildings, and compact development close to existing services and public transport.

A significantly higher threshold should apply before development takes place on strategically important green belts, prime agricultural land capable of contributing to domestic food production, areas important for biodiversity and community wellbeing, or land with significant present or future flood risk.

In that context, we are concerned by recent decisions in Fingal to rezone green-belt areas despite significant concerns about flood risk and local opposition. Decisions about housing and land use need to be demonstrably consistent with Ireland’s climate mitigation and adaptation objectives.  Fingal approves 5,000 new homes amid ‘significant’ flood risk concerns in green belt areas | Irish Independent. 

Agriculture, land use and food security

The agricultural sector requires more fundamental structural attention in CAP26.

Much existing climate policy in agriculture focuses on reducing emissions from the current production model. While improved efficiency is valuable, it will not by itself address the scale of the transition required.

Ireland must actively support greater agricultural diversification, including substantially increased horticulture, tillage, organic farming, agroforestry and production of plant foods for the domestic market.

This would contribute not only to emissions reduction but to food security and resilience. Ireland currently devotes a very large proportion of its agricultural land to grassland-based livestock production, while remaining heavily dependent on imports for many foods that could be produced domestically.

The Climate Change Advisory Council has itself identified agricultural diversification as vital and called for policies supporting organic production, expanded tillage and agroforestry.

CAP26 should therefore set a clear direction for agricultural policy and public funding. State and EU agricultural supports within Ireland’s influence should increasingly reward measurable outcomes including lower greenhouse gas emissions, reduced reliance on synthetic nitrogen, healthy soils, water protection and retention, biodiversity, crop diversity and production contributing to a resilient food system.

Any such transition must be fair to farmers. Farmers whose businesses have developed within a policy and subsidy system that has encouraged livestock production need practical advice, secure routes to market, investment support and adequate financial incentives to make alternative land uses economically viable.

See also The Lie of the Land: A morning with John Gibbons | Sustainable Skerries   

Conclusion

Ireland is substantially off course for its legally binding 2030 climate targets at the same time as the impacts of climate change are becoming increasingly evident.

CAP26 therefore needs to do more than add further actions to an already extensive list. It must identify and prioritise the structural changes capable of closing the emissions gap, build adaptation into the decisions and infrastructure being made today, and establish clear mechanisms for measuring whether implementation is succeeding.

For Sustainable Skerries, the priorities are clear: high-impact action; agricultural and land-use transition; climate-resilient development; management of energy and material demand as well as renewable supply; reduced car dependency; protection of biodiversity alongside rapid renewable-energy deployment; and strong delivery and accountability across all sectors.

We welcome the opportunity to contribute to this consultation and hope that these comments are useful in shaping a Climate Action Plan capable of delivering the scale and speed of change now required.

Sustainable Skerries Submission on Climate Action Plan 2026 Priorities

Sustainable Skerries, a committee of the Skerries Community Association based in North County Dublin, welcomes the opportunity to respond to the public consultation on the next update to Ireland’s Climate Action Plan.

The context for Climate Action Plan 2026 is stark. The EPA’s May 2026 projections indicate that, even with full implementation of currently planned policies and measures, Ireland would achieve only about a 25% reduction in greenhouse gas emissions by 2030, against a legally binding national target of 51%. The second carbon budget for 2026–2030 is projected to be exceeded by between 53 and 82 Mt CO₂eq.

At the same time, the effects of a changing climate are becoming increasingly difficult to consider in the abstract. Met Éireann reports that July 2026 was Ireland’s second-hottest July since 1900 and the driest July on record, with rainfall nationally at just 17% of the 1991–2020 average.

We therefore agree that CAP26 must focus strongly on implementation and on the actions capable of having the greatest impact. In particular, we believe six overarching principles should guide the Plan:

1. Ireland must prioritise high-impact structural change. CAP26 should distinguish clearly between actions capable of materially reducing national emissions and worthwhile supporting activities whose primary benefits are awareness, biodiversity, adaptation or community resilience.
2. Agricultural policy must move beyond improving the greenhouse-gas efficiency of existing production towards diversification and land-use change. The State should provide much greater support for horticulture, tillage, organic farming, agroforestry and other forms of ecologically beneficial food production, while ensuring a fair transition for farmers currently dependent on livestock production.
3. Climate adaptation must become a design requirement now. Housing, infrastructure and spatial planning must be based on the climate Ireland is likely to experience during their lifetime, including increased risks from drought, water scarcity, intense rainfall, flooding, overheating and coastal impacts.
4. Energy and material demands matter as well as supply. Renewable energy must expand rapidly, but CAP26 should also constrain avoidable growth in energy and material consumption, particularly where large new energy loads could undermine decarbonisation elsewhere.
5. Transport policy should reduce car dependency in general, not merely fossil-fuel-car dependency. Spatial planning that reduces the need to travel, strong local services, public transport and active travel should come first, with EVs forming part of the solution for the motorised journeys that remain.
6. Climate action and biodiversity protection must not be traded against each other. Renewable energy development needs to be accelerated through strategic spatial planning, grid investment and more efficient procedures, while retaining strong ecological safeguards.

Delivery and accountability must underpin all six priorities. Given the scale of the projected gap to Ireland’s legally binding climate targets, Ireland’s problem is no longer a shortage of worthwhile aspirations. CAP26 must ensure that the changes needed actually happen.

Delivery, measurement and local implementation

Many of the points raised in our previous submission to the consultation on Climate Action Plan 2024 remain relevant.

Actions in local authority climate action plans should be linked wherever possible to specific, measurable, achievable, relevant and time-bound goals. We welcome the progress Fingal County Council has made to date, as outlined in its Climate Action Plan Progress Report of May 2026. However, where measurable targets are absent, it can be difficult to assess the scale of the impact achieved.

Local authorities need effective ways of determining which actions are having the greatest mitigation or adaptation impact so that limited funding, staff time and community effort can be directed accordingly. Reporting that an action has commenced or progressed is not, on its own, sufficient to demonstrate climate impact.

This does not mean that activities primarily supporting climate literacy, biodiversity, community resilience or engagement are not valuable. They can be extremely worthwhile. However, they should be identified and evaluated according to the outcomes they are intended to achieve rather than treated as equivalent to actions capable of substantially reducing greenhouse gas emissions.

Electricity demand, renewable energy and data centres

We remain concerned about the impact of rapidly growing data centre electricity demand. The Climate Change Advisory Council reported in 2026 that data centre electricity demand had grown from approximately 5% of electricity demand in 2015 to more than 20%.

As highlighted in the Oireachtas Report on Barriers to Achieving Climate Targets 2026–30, CAP26 should prioritise immediate and long-term electricity demand-management strategies, particularly in respect of very large energy users. 

The underlying principle should be that Ireland cannot rely solely on continually increasing renewable electricity generation while allowing avoidable electricity demand to grow without constraint. Increased electricity demand arising from necessary electrification of heating, transport and other fossil-fuel uses is different from discretionary additional demand from new large energy users.

New large energy users should therefore be required to demonstrate that their demand can be accommodated without jeopardising Ireland’s carbon budgets, security of supply, grid resilience or the decarbonisation of existing electricity demand. Where renewable generation is required to support new developments, this should represent genuinely additional renewable capacity rather than simply competing for renewable electricity already needed to decarbonise the existing economy.

We also remain concerned about evidence that increasing data centre electricity demand may contribute to energy affordability pressures for households and communities. 

See also Friends of the Earth Cost of Data Centre Growth in Ireland

Aviation

We ask that decarbonisation of the aviation sector is addressed more fully in CAP26. Technological improvements and alternative fuels should form part of the response, but CAP26 should also consider demand-management measures rather than assuming that continued growth in aviation demand can be reconciled with Ireland’s carbon budgets solely through future technological change.

Community engagement and public support

Community engagement is necessary for climate action but is not sufficient. People also need appropriate infrastructure, services and practical opportunities to change their behaviour.

CAP26 should therefore explicitly recognise that responsibility cannot simply be transferred to individuals and communities without enabling conditions. Local authorities and community organisations need adequate financial, technical and administrative support.

Our experience in Skerries suggests, for example, that retrofitting community buildings can be unnecessarily difficult. CAP26 should include measures to identify and remove the practical, regulatory and financial obstacles facing community organisations seeking to retrofit buildings or undertake other substantial climate projects.

There is also a need to understand better why climate measures that enjoy broad support in principle can encounter strong opposition when particular projects are proposed.

Recent examples in Skerries include debate around the proposed North Irish Sea Array offshore wind development and Fingal County Council’s Active Travel Plan.
Residents raise concern as Ireland’s six new offshore wind farms move closer to reality and regarding Fingal County Council’s Active Travel Plan Over 600 submissions made to Fingal County Council over Skerries Active Travel Plan | Irish Independent.
These are very different projects, and objections should not automatically be interpreted as opposition to climate action. Concerns may arise from genuine environmental or biodiversity issues, perceived financial or practical impacts, lack of trust or participation, disagreement about particular designs, or misinformation about climate change.

CAP26 should prioritise research into such experiences and systematically share lessons about early public participation, communication, decision-making and conflict resolution. Ireland needs to become better at distinguishing legitimate concerns that should influence project design from barriers that can be overcome through better information, consultation or support.

Climate-resilient buildings and infrastructure

It is generally easier and more cost-effective to incorporate climate mitigation and adaptation measures at the beginning of a development than to retrofit them later.

Buildings constructed in 2026 may still be in use towards the end of this century. Building regulations and planning requirements should therefore be based not only on present conditions but on the climate those buildings are likely to experience throughout their lifetime.

CAP26 should prioritise the development and strengthening of legislation and building standards covering measures such as:

• renewable energy generation and low-carbon heating;
• high levels of energy efficiency;
• water efficiency;
• rainwater harvesting and storage;
• greywater reuse where appropriate;
• sustainable drainage and management of intense rainfall;
• resilience to flooding;
• passive protection against overheating;
• resilience to extreme weather; and
• appropriate provision for EV charging.

The Climate Change Advisory Council has similarly highlighted the need for greater flood protection, improved water-use efficiency, indoor thermal regulation and greater resilience to extreme wind.

Climate adaptation should no longer be treated mainly as something to be added to existing buildings and infrastructure after problems arise. It should become a fundamental requirement of new development.

Transport and spatial planning

Transport remains Fingal’s second-largest source of emissions. However, transport policy should not focus primarily on replacing internal-combustion-engine cars with electric cars.

CAP26 should prioritise a hierarchy of reducing the need for motorised journeys; shifting journeys towards walking, cycling and public transport; and electrifying the motorised transport that remains.

Land-use and transport planning should therefore increasingly make it possible for people to live close to employment, schools, shops, services and amenities. Compact, walkable towns and neighbourhoods with strong local services can reduce car dependency while also improving quality of life.

Towns such as Skerries also need substantially better local public transport. More frequent local bus services, ideally using zero-emission vehicles, could reduce car dependence without many of the long infrastructure lead times associated with larger transport projects. There is local support for improved services of this kind.

As highlighted in the Oireachtas Report on Barriers to Achieving Climate Targets, measures such as additional EV bus stock, school bus provision and rural bus networks can be frontloaded without the infrastructural delays affecting major transport projects, and should therefore be prioritised.

CAP26 should therefore place greater emphasis not simply on the number of EVs on Irish roads but on measurable reductions in car dependency, private vehicle kilometres and the proportion of everyday journeys that require an individual motorised vehicle.

Renewable energy and biodiversity

Ireland urgently needs much more renewable electricity and the grid infrastructure required to use it effectively. Planning and delivery processes need to become faster and more predictable.

However, climate action and biodiversity protection should not be treated as competing objectives. Poorly located renewable-energy infrastructure can create genuine environmental impacts, while lengthy and adversarial project-by-project disputes also jeopardise Ireland’s ability to meet its renewable-energy targets.

CAP26 should therefore support stronger strategic spatial planning for renewable energy, identifying suitable and environmentally sensitive areas at an early stage, supported by robust ecological evidence and meaningful community participation.

This should enable Ireland both to accelerate renewable-energy deployment and to uphold strong environmental and biodiversity obligations.

Land use, housing and climate resilience

We recognise the urgent need for additional housing. However, meeting housing need should not mean that climate adaptation, food security, biodiversity and flood resilience are given insufficient weight in planning decisions.

CAP26 should promote a clear hierarchy that prioritises the development of existing serviced and residentially zoned land, brownfield and infill sites, vacant and underused buildings, and compact development close to existing services and public transport.

A significantly higher threshold should apply before development takes place on strategically important green belts, prime agricultural land capable of contributing to domestic food production, areas important for biodiversity and community wellbeing, or land with significant present or future flood risk.

In that context, we are concerned by recent decisions in Fingal to rezone green-belt areas despite significant concerns about flood risk and local opposition. Decisions about housing and land use need to be demonstrably consistent with Ireland’s climate mitigation and adaptation objectives.  Fingal approves 5,000 new homes amid ‘significant’ flood risk concerns in green belt areas | Irish Independent. 

Agriculture, land use and food security

The agricultural sector requires more fundamental structural attention in CAP26.

Much existing climate policy in agriculture focuses on reducing emissions from the current production model. While improved efficiency is valuable, it will not by itself address the scale of the transition required.

Ireland must actively support greater agricultural diversification, including substantially increased horticulture, tillage, organic farming, agroforestry and production of plant foods for the domestic market.

This would contribute not only to emissions reduction but to food security and resilience. Ireland currently devotes a very large proportion of its agricultural land to grassland-based livestock production, while remaining heavily dependent on imports for many foods that could be produced domestically.

The Climate Change Advisory Council has itself identified agricultural diversification as vital and called for policies supporting organic production, expanded tillage and agroforestry.

CAP26 should therefore set a clear direction for agricultural policy and public funding. State and EU agricultural supports within Ireland’s influence should increasingly reward measurable outcomes including lower greenhouse gas emissions, reduced reliance on synthetic nitrogen, healthy soils, water protection and retention, biodiversity, crop diversity and production contributing to a resilient food system.

Any such transition must be fair to farmers. Farmers whose businesses have developed within a policy and subsidy system that has encouraged livestock production need practical advice, secure routes to market, investment support and adequate financial incentives to make alternative land uses economically viable.

See also The Lie of the Land: A morning with John Gibbons | Sustainable Skerries   

Conclusion

Ireland is substantially off course for its legally binding 2030 climate targets at the same time as the impacts of climate change are becoming increasingly evident.

CAP26 therefore needs to do more than add further actions to an already extensive list. It must identify and prioritise the structural changes capable of closing the emissions gap, build adaptation into the decisions and infrastructure being made today, and establish clear mechanisms for measuring whether implementation is succeeding.

For Sustainable Skerries, the priorities are clear: high-impact action; agricultural and land-use transition; climate-resilient development; management of energy and material demand as well as renewable supply; reduced car dependency; protection of biodiversity alongside rapid renewable-energy deployment; and strong delivery and accountability across all sectors.

We welcome the opportunity to contribute to this consultation and hope that these comments are useful in shaping a Climate Action Plan capable of delivering the scale and speed of change now required.