Sustainable Skerries made a submission to the draft Climate Action Plan (see below).

The acknowledgement stated: “All submissions will be reviewed by the Department of the Environment, Climate and Communications, and may inform updates to the final version of this year’s Plan.”

Let’s hope it will make a difference! Here is our submission:

Sustainable Skerries, a committee of the Skerries Community Association, based in North County Dublin, welcomes the opportunity to comment on the draft Climate Action Plan 2024 (‘CAP24’). It has many positive aspects, including increased focus on the role of local authorities and citizen engagement, and additional actions and key performance indicators compared with CAP23. Some suggestions to further strengthen CAP24 are set out below.

1. The role of local authorities and tracking of their action plans
   In October 2023 Sustainable Skerries responded (here) to the Fingal County Council Draft Climate Action Plan 2024-2029 (‘FCC’s draft plan’). In that context, it is positive that CAP24 recognises the key role of local authorities in addressing climate change and the need for training and capacity building for local authority staff and elected members (chapter 19).
   On p.385 CAP24 states “local authorities will devise an approach for the annual implementation of actions, track progress through KPIs, and report on progress at local and national levels”. Sustainable Skerries felt that FCC’s draft climate action plan could be improved in that regard. For that reason, we suggest that at national level, a demand is added that all actions in the local authority climate action plans be linked to specific, measurable, achievable, relevant and time-bound goals. Multiple actions in the draft Fingal plan are currently too vague with no targets specified.
   Actions in all local authority plans must thus 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. Additionally, it is meaningless to report that “20% of all actions have progressed” if any specific action only moves the needle a tiny bit. Indeed, there is no indication across the multitude of actions in Fingal’s draft plan 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. Local authority action plans should be mandated to include prioritisation. This should also help with prioritisation and informing where budgets are spent. KPIs need appropriate target ranges set in advance. We call upon national agencies to support local authorities in developing meaningful KPIs.
2. The impact of data centre electricity demand on emissions
   Several submissions to FCC’s draft plan, including from Sustainable Skerries, raised concerns about the contribution of data centres to emissions. We note that CAP24 mentions data centres explicitly only once (p.52), even though the SEAI’s National Energy Projections 2023 highlight that the achievement of the electricity sector’s carbon budget will be heavily influenced by datacentre demand. We request that section 12.4.1.3 of CAP24 on electricity demand management explicitly covers actions related to datacentre electricity demand.
3. Decarbonising the aviation sector
   We note that Dublin Airport and the impact of air travel on greenhouse gas emissions are not mentioned at all in FCC’s draft plan, again this was raised in several submissions to FCC. We note that CAP24 recognises the importance of international co-operation, including EU regulations, in decarbonising the aviation sector. However, the only concrete measure that appears to be mentioned is the use of sustainable aviation fuels (p.281). However, there is still considerable uncertainty as to the emissions reduction impact from sustainable aviation fuels, as well as other challenges
   related to sourcing them, therefore experts believe that other mitigation measures also need to be considered e.g., Sustainable Aviation Fuel: How Sustainable Is It Really? | IBA. This includes aviation demand management, on which CAP24 is silent, even though the DAA has requested permission for an increase in the passenger cap on Dublin airport, which appears incompatible with climate targets – Plans to expand Dublin Airport clash with global effort to slow climate change – Dublin Inquirer. We ask that the topic of decarbonisation of the aviation sector be more fully explored in CAP24, including consideration of additional actions such as the potential for demand management.
4. Community Engagement
   Sustainable Skerries welcomes chapter 9 on Citizen Engagement and the expected outcome of “delivering the vision of climate action for Ireland through the shared values of fairness, collaboration and positive change” (p.99). Like FCC’s draft plan, CAP24 focuses actions in this area on communication and engagement. These are necessary but not sufficient for action, people also need to have the facilities/infrastructure to be empowered to affect change. We ask that this is more explicitly recognised in CAP24, and sufficient support provided to local authorities and to community groups to enable them to implement new facilities such as the provision/expansion of community repair and recycling spaces, to facilitate behavioural change.
   It is important to recognise that high emitting sectors such as transport and agriculture, and the increased usage of data centres, are providing goods and services to consumers and households. Therefore significant change is required at the household and community level to achieve carbon budgets. It is positive that CAP24 recognises the need for further social and behavioural research to identify and address barriers to policy implementation (p.111). We suggest that more emphasis is placed on this aspect of CAP24, as without overcoming social barriers (such as concerns regarding financial costs and practical inconvenience or mistaken beliefs about climate change), the many technical solutions proposed are unlikely to be successful. Additionally, whilst the community climate action fund is welcome, community groups are usually time-constrained volunteers, who need practical as well as financial support to contribute to climate action, e.g., direct access to specialist
   expertise in relevant areas or the possibility of using climate-action funds for paying for admin support .
   Conclusion
   Sustainable Skerries recognises the many positive aspects of CAP24 and acknowledges the considerable work that has gone into producing it. We hope that our comments are useful in improving it even further.