My Clean Air Strategy Public Consultation Submission
04 May 2022
Senator Marie Sherlock
Clean Air Strategy Public Consultation,
Air Quality Division,
Department of the Environment, Climate and Communications,
Submitted via email: firstname.lastname@example.org
3rd May 2022
Submission on the Clean Air Strategy for Ireland
To the Members of the Air Quality Division,
I welcome the opportunity to share my thoughts on this vitally important issue.
At the outset, let me say that the adoption of an effective Clean Air Strategy is essential to the future wellbeing of people in all parts of the country.
I believe we must make sure to recognise the serious impact poor air quality has on certain communities, such as those of Dublin’s North Inner City and the communities located inside the canals in Dublin. High traffic volumes into the city are a major contributor to the prevalence of poor air quality of the area, making it even more important to promote active travel and sustainable, affordable home heating solutions for these communities and others like them.
Furthermore, the Government’s strategy must set a clear target and path to adoption of the World Health Organisation's air quality standards that were revised in 2021. The scientific evidence is unambiguous that lives can be saved and illness prevented or mitigated if there are reductions in harmful particulates in the air that we live and breathe in.
My observations are set out below. I hope they will be useful in finalising the Clean Air Strategy.
- Expanding Existing Strategic Priorities
Recommendation: A target of genuinely clean air for all must be explicitly set down. The strategy must clearly prioritise areas which currently have lower air quality, and to improve public awareness of how their actions and the actions of the State can contribute towards improving our air quality. In effect, strategic priorities number 1 to 5 in the existing documents must be expanded to include the above.
The five keys strategic priorities outlined in the document are welcome, however I would suggest that the scope of Priority 1 and 5 could be usefully expanded.
For Priority 1 (“ensure continuous improvements in air quality across the country”) I would suggest that the goal should not only be continuous improvement, but the ultimate delivery of genuinely clean air for all. Furthermore, while improvements should of course be made all across the country, some reference is necessary on the need to prioritise areas where air quality is currently poor.
I would propose new wording for Priority 1 to read: “To ensure continuous improvements in air quality across the country, with a particular emphasis on areas where air quality is currently poor, and with the ultimate goal of delivering genuinely clean air for all.”
For Priority 5, I strongly welcome the emphasis placed on improving public awareness of the importance of clean air. However, I believe it is also important to raise awareness of the State’s plans in this area, and of the potential role of communities and individuals in helping to achieve these goals, and where necessary holding the State to account should targets not be met.
I would suggest modifying the current text of Priority 5 to read: “To promote and increase awareness of the importance of clean air, of existing and future air quality targets set by Government, and of the role that individuals and communities can play in ensuring these targets are met.”
- Ensuring Better Availability of Emissions Data
Recommendation: Include an additional strategic priority which sets out the need for more air quality monitoring, including by installing new monitors in densely populated, high-traffic areas communities such as Dublin’s Northside.
While Strategic Priority 3 does call for a wider evidence base on sources of air pollution, I believe that the strategic priorities of the Clean Air Strategy must be more specific. We must include that a key goal of this strategy should be to increase the active monitoring of high-traffic areas for air quality.
In practical terms, this should include significant expansion of the number of active air monitoring stations across the country, and within the Northside of Dublin in particular. At the moment, the Air Quality Index for Health (AQIH) informs much of our understanding of air quality in Ireland. And yet, the Environmental Protection Agency’s current list of monitoring stations includes none between the River Liffey and the River Tolka east of the Phoenix Park.
It is not acceptable that such densely populated areas, which act as a gateway to the city through three major arteries in Drumcondra, Phibsborough and Stoneybatter, are not currently monitored on a sustained basis.
From the Clean Air Together citizen science project, we know that in at least one location on the Phibsborough Road, Nitrogen Dioxide levels were three times the levels recommended by the WHO. However, these results are not part of a wider systemic monitoring of air quality levels in the city - it is vital that they should be into the future.
An additional strategic priority should therefore be added, setting out the clear aim of securing sufficient air quality monitoring stations to give a fully detailed and accurate picture of air quality in all parts of the country, especially in densely populated, high-traffic areas such as North Dublin City.
- Promoting a Strong Policy Response for Better Air Quality
Recommendation: That the Clean Air Strategy does all it can to promote an urgent and comprehensive policy response to the challenge of poor air quality: including through promotion of active transport, reduction of private car journeys within urban areas, consideration of Low Emission Zones, meaningful support for retrofitting and sustainable home heating solutions, targeted support for lower-income communities and those most at risk from lower air quality, and greater dissemination and promotion of air quality research and monitoring data.
It is my strong belief that, by ensuring a more comprehensive view of air quality data, as set out in part two of this submission above, we will ensure a greater urgency in taking the necessary tangible policy actions.
The poor level of air quality in parts of our country is, along with housing, one of the greatest challenges that must be headed off in the immediate future.
It will be an essential mark of this Strategy’s success, or otherwise, that we significantly increase the opportunities for active travel and ensure a major decrease in total car journeys within urban areas. Ultimately, the improvement of air quality can only be guaranteed through serious, large-scale actions to incentivise cycling, public transport use and sustainable, affordable home heating solutions in households within Dublin City.
Initiatives such as Low Emission Zones should be considered, as should serious expansion of existing retrofitting programmes, especially for lower-income households. At the heart of any action must be supports for the least advantaged who are, on average, the most exposed and the least able to take on the cost of mitigating actions.
The implementation of this Strategy should set out ways in which those communities most at risk of poor air quality can be meaningfully engaged with to ensure policy actions which are effective, fair and receive meaningful buy-in from those most impacted upon.
More publication of real-time localised air quality information by public bodies would also be key in increasing public awareness and activity on improving air quality, as would promotion of research to examine the real, specific impacts of poor air quality on health, wellbeing and community life.
Thank you for taking the time to review this submission. I wish you the best in finalising this important Strategy.
Senator Marie Sherlock