My submission to the consultation on the National Clean Air Strategy

Another gruesomely last minute submission to what was too important a consultation not to have an input to.  Submissions on the National Clean Air Strategy were invited by the Department of Communications, Climate Action and the Environment.  It would be rewarding if even some of the actions asked for below were given credence in the final Strategy.

Cllr Marcia D’Alton
22 Hillcrest,
Pembroke Wood,
Passage West,
Co. Cork.

To whom it may concern

I should be grateful if the following comments would be taken into account in the drafting of the National Clean Air Strategy.

All Environmental Impact Statements accompanying planning applications should be required to measure down to at least PM1.  At present, planning applications rarely discuss particulates smaller than PM2.5.

Establish a network of units monitoring air pollution in real time so that communities can be informed of air quality in their local area.  At present, the network of real time monitoring is abysmal and not at all in compliance with Ireland’s requirements under European legislation.  Critical parameters would include PM10, PM2.5, PM1 and ozone.  Real time results would be made fully accessible to all through the internet.

Install comprehensive ambient air monitoring units in all Strategic Employment Areas and zones of industrial development.

Through the planning process, establish a minimum acceptable distance of 300 metres between schools and busy roads.

Develop a policy of constructing ring roads around cities, thereby keeping traffic from travelling unnecessarily through residential areas.  Urban motorways through residential areas must be discouraged at all costs.  As mentioned in the discussion document, residential areas already deal with the build-up of residential pollutants.  It is absolutely unacceptable that they would also have to deal with pollutants from traffic on urban motorways.

Encourage dense planting of mature trees along major roads to act both as a visual/psychological barrier between traffic and residential homes and as a pollutant sink.

Extend the financing of significantly enhanced public transport to areas outside of Dublin.  At present, many living in suburban homes in cities outside of Dublin cannot take their cars off the road long enough to get them valeted.  A congestion charge as suggested in the discussion document would be entirely unacceptable when no reasonable alternative to the private car is on offer.  That is the case for those living in most urban areas outside of Dublin.

Facilitate the development of cycling as a real alternative to the private car.  Policy and funding needs to stop considering cycling within periurban as recreational.  In my Ballincollig-Carrigaline Municipal District of County Cork, greenways compete for the same tiny funding pot as tourism routes such as the Waterford Greenway.  Yet the level of bicycle/pedestrian traffic they are expected to carry in what are generally more restricted spaces is vast multiples of that which the more rural routes carry.  They need separate consideration and additional, dedicated investment.

Most major ports are adjacent to residential areas.  Yet there is never any independent ambient air monitoring to assuage affected residents.  This is especially critical for ports handling bulk cargo.  It is imperative that all major ports would be obliged to install real-time ambient air monitoring to measure parameters representative of the by-products of engine and generator emissions.  It is equally imperative that all ports, regardless of size, which handle bulk cargo would be obliged to install real-time monitoring to measure levels of particulate in ambient air.

Shoreside electrical power to be provided at all ports which ships berthing overnight should be obliged to use in preference to their own generators.

Often the most polluting offenders in a port situation are partner companies conveying, handling and storing dusty bulk cargo in warehouses and grain stores adjacent to the port.  These companies are not subject to any form of monitoring either by the Environmental Protection Agency or the local authority.  Nor at the time of planning application are they considered to be potential pollutors under the Air Pollution Act.  This must change.

Disappointing to see that waste to energy gets only a glancing mention in the discussion document.  National waste policy sets an upper acceptable limit for the combined capacity of waste to energy facilities to be provided in Ireland.  Taking both constructed and permitted facilities into account, this national upper capacity limit has been reached.  Therefore in accordance with current waste policy, planning permission should not be granted for any additional waste to energy facilities in Ireland.  Energy from the combustion of residual waste is not clean energy.  Feedstock is unpredictable and dirty.  Emissions quality is utterly dependent on the efficacy of a series of scrubbers and other pollution control equipment.  Energy conversion into electricity is grossly inefficient.

European policy is that waste combustion in incinerators must always be classified as waste disposal (D10) unless it can prove that it is energy recovery (R1).  In Ireland, we grant planning permission to incinerators merely on the promise of their delivering R1.  It is essential that Irish policy reflects European policy in this regard and that the infrastructure necessary to efficiently use both the heat and electricity generated by the waste combustion process would form an integral part of the planning application for any new incineration facility.

Vastly improved resourcing for local authorities to carry out their functions under the Air Pollution Act is essential.  At present, they are barely struggling.  Perhaps consider an environmental fund at national level financed via pollution levies which could, over a defined period of time, be used to fund the setting up of properly resourced air monitoring functions within local authorities.

We have no strategies in place in this country by which to tackle existing pollution.  For example, ambient air monitoring in the village of Monkstown on the shores of Cork Harbour, was conducted by the EPA over a 7 month period during 2007/2008.  It found that levels of PM10 were high.  The resulting recommendation was that PM10 would be monitored continuously.  In the following 12 years, traffic has multiplied, permission has been granted for a major port facility nearby, third party grain storage and handling has increased, new industrial facilities have established and planning permission is now being sought to convey all port goods by road via an urban motorway.  Yet ambient levels of any size of particulate matter have never been measured again.

I attach a motion I proposed to Cork County Council in February 2016 requesting real-time ambient air monitoring in Cork Harbour.

Air monitoring in Cork Harbour


Marcia D’Alton.
Independent Member, Cork County Council

Mobile: 085 – 7333852
Twitter: @marciadalton