An Taisce The National Trust for Ireland
- Date submitted: 1 Nov 2011
- Stakeholder type: Major Group
- Name: An Taisce The National Trust for Ireland
- Submission Document: Download
General Contenta) What are the expectations for the outcome of Rio+20, and what are the concrete proposals in this regard, including views on a possible structure of the Outcome document? ? A recommitment to fully implement those principles of the Earth Summit 1992 which have not yet been completed, both nationally and internationally.
? To prioritize those principles that have become even more critical, namely biodiversity and habitat loss, measures to counteract Climate Change, eradication of poverty, greater emphasis on Local Agenda 21 and 'bottom up' sustainability measures.
? A firm principle on strong governance and oversight to ensure audit and implementation of the measures agreed.
b) What are the comments, if any, on existing proposals: e.g., a green economy roadmap, framework for action, sustainable development goals, a revitalized global partnership for sustainable development, or others? N/A
c) What are the views on implementation and on how to close the implementation gap, which relevant actors are envisaged as being involved (Governments, specific Major Groups, UN system, IFIs, etc.); N/A
d) What specific cooperation mechanisms, partnership arrangements or other implementation tools are envisaged and what is the relevant time frame for the proposed decisions to be reached and actions to be implemented? N/A
Specific Elementsa) Objective of the Conference: To secure renewed political commitment for sustainable development, assessing the progress to date and remaining gaps in the implementation of the outcomes of the major summits on sustainable development and addressing new and emerging challenges. Contributions could include possible sectoral priorities (e.g., (e.g., energy, food security and sustainable agriculture, technology transfer, water, oceans, sustainable urbanization, sustainable consumption and production, natural disaster preparedness and climate change adaptation, biodiversity, etc.) and sectoral initiatives that contribute to integrate the three pillars of sustainable development could be launched and endorsed at Rio+20. 1.2 Irish Constitutional and legislative provision for sustainable development.
The provision of Constitutional amendment to incorporate the revised and updated sustainable development declaration which will emerge from Rio +20 process.
Legislative provision for sustainable development as an overarching objective, parallel to national climate change legislation with mandatory greenhouse gas emission reduction targets. Revision of remit of Government departments state and Statutory boards and Government share-hold controlled companies, including Bord Na Mona and Coillte with sustainable development as overriding objective.
1.3 Reducing Irelands global resource consumption and emission footprint.
A range of global emission and resource consumption measurements now exist which all establish the unsustainability of continuing consumptions and emission levels. The 2006 National Footprint Network table (Appendix 1) is particularly striking in illustrating the disparity between the developed and the poorest countries. Global footprint calculation is based on a range of measurements including arable land use area, water use, fossil fuel and mineral resource use, calculating point of origin and transboundary impacts.
The October 2010 Living Planet report identified Ireland as having the tenth highest global footprint
The Living Planet report looks at the changing state of ecosystems, consumption of natural resources and the implications for the future of the world.
Overall, the report concludes natural resources are being consumed faster than the Earth is replenishing them. People are now living lifestyles which would require one and a half planets to sustain, though there are significant differences between rich and poor nations.
The report, carried out by the World Wildlife Fund, examines the number of ?global hectares? ? the amount of biologically productive land and water available per person on the planet ? that countries need.
Irish people on average use just over six global hectares per person, more than double the demand of some EU countries, such as Hungary and Romania. The worst offender is the United Arab Emirates.
Irish per capita resource consumption levels and global foot impacts are at a comparable level to the US and Australia. Post boom Ireland retains in high per capita levels of energy consumption, consumer and household goods and clothing, meat and processed food.
2.2 Sustainable use of the components of biodiversity,
All human activities, including all our economic activities, take place inside, and cannot exceed, the carrying capacity of our environment. The carrying capacity of our environment is dependent on the healthy functioning of our biodiversity and ecosystems. From an economic perspective, numerous attempts have been made to understand the value of biodiversity to humanity in terms of ecological goods and services for instance insect pollination, water regulation and purification, carbon storage.
The Millennium Ecosystem Assessment (MA) assessed the condition of 24 of the earth?s natural systems that it considers humanity?s ?life support systems?. It concluded that over the previous 50 years, four of these systems have shown some improvement, fifteen are in serious decline, and five are in a stable state on a worldwide basis, but threatened in some parts of the world. The establishment of the TEEB (The Economics of Ecosystems and Biodiversity) study (http://www.teebweb.org/) is another initiative to highlight economic benefits of biodiversity, cost of biodiversity loss and ecosystem degradation, and make practical management recommendations.
Yet other reasons to conserve biodiversity are equally valid and must not be lost in the rush to weigh up its economic value to humans. There is also our ethical responsibility to conserve biodiversity and facilitate a shift toward societal respect for nature. In the words of Richard Frankham ?The ethical justifications for conserving biodiversity are simply that one species on Earth does not have the right to drive others to extinction, analogous to abhorrence of genocide among human population?.
The value of crop pollination in Ireland by all pollinating insects has been estimated as ?53million per year in Ireland . Unfortunately, the current status of Irish pollinators appears to be in decline, with 30% of the wild bees and 18% of butterfly species in Ireland considered threatened according to the International Union for Conservation (IUCN).
To achieve food security in face of an ever growing population, Ireland and the world, will require large areas of fertile land. However increasing pressures such as urbanisation, afforestation, industry, erosion and overgrazing are putting soil quality at risk. As yet there is no program to monitor and protect this essential resource in Ireland. In the European Union it has been estimated that soil deterioration costs 38 billion a year, however to date; no such figure appears available for Ireland.
b) Green economy in the context of sustainable development and poverty eradication: views regarding how green economy can be a means to achieve sustainable development in its three dimensions, and poverty eradication; what is its potential added value; experience to date, including what has worked and how to build upon success, what are the challenges and opportunities and how to address the challenges and seize opportunities, and possible elements of an agreement in outcome document on a green economy in the context of sustainable development and poverty eradication N/A
c) Institutional framework for sustainable development: Priorities and proposals for strengthening individual pillars of sustainable development, as well as those for strengthening integration of the three pillars, at multiple levels; local, national, regional and international. N/A
d) Any proposals for refinement of the two themes. Recall that Resolution 64/236 describes the focus of the Conference: "The focus of the Conference will include the following themes to be discussed and refined during the preparatory process: a green economy in the context of sustainable development and poverty eradication and the institutional framework for sustainable development". N/A
Full SubmissionAn Taisce ? The National Trust for Ireland Tailor?s Hall, Back Lane, Dublin 8 31st October 2011 RE: UN Submission re Rio +20 An Taisce, The National Trust for Ireland, welcomes this opportunity for public consultation on Ireland?s progress since the 1992 Earth Summit in Rio de Janeiro (Rio 1992). An Taisce was established in 1948 and is Ireland?s oldest voluntary environmental organisation. It is national organisation and a key consultation prescribed body under a number of environmental and planning, acts and regulations in Ireland. As such An Taisce has been uniquely positioned to observe the ongoing developments in Ireland?s natural environment since Rio and during the economic and construction boom of he ?Celtic Tiger?. There is an urgent need to ensure that environmental issues are embedded in all relevant legislation both on a national and international level. Measures should be introduced to assess practices carried out throughout the system e.g. agriculture, forestry, planning etc. Procedures for appropriate monitoring of impacts along with relevant regulations and should be introduced plus provisions for strict enforcement to ensure compliance when found necessary together. The establishment of a Court for Environmental Justice would be an appropriate development as would the strengthening of UNEP. A constitutional right to a healthy environment should be enshrined in law. Since the adoption of the 1992 Rio Declaration, Ireland had the fastest population increase in the EU. The unprecedented physical and infrastructural investment which occurred between the mid 1990?s and 2007 failed to address the principles of the Rio Declaration. Development was instead underpinned by a flawed economic growth based model disregarding resource consumption, climate emissions and debt accumulation. There was significant lack of initiative in protecting Ireland?s most internationally significant Habitats and accordingly breaking the biodiversity convention. This particularly applies to the introduction of a ten year derogation to accommodate continued mechanised peat cutting in Special Area of Conservation designated raised bogs. Transport investment was focused on over-scaled airport terminal capacity and a motorway programme which has accelerated car based urban sprawl and made rail travel slower than inter regional road travel times. The late implementation of EU building energy performance rating standards and lack of any significant retrofit investment has left a highly energy inefficient building stock. Investment in a new generation of 3 peat burning power stations created an additional carbon burden on top of an already per capita emission level. Ireland?s per capita emissions at over 16 tonnes are twice that of Sweden. Much of the focus of Tourism investment during the boom years was for visitor accommodation and golf resort development in sensitive landscape locations or country house parklands. This can undermine the key asset base which makes Ireland attractive in the first place. Government Departments and State Agencies and companies failed to incorporate sustainably into their core remit, policy and decision making. In many cases policies or actions promoted by the former Department of the Environment, Heritage and Local Government were disregarded. Department of the Environment, Heritage and Local Government funded a television advertising campaign recommending lower driving speeds to reduce greenhouse gas emissions, while the Department of Transport increased motorway speed limits from 100kph to 120kph, thereby increasing greenhouse gas emissions and further undermining viability and use of public transport. In 2008 the Department of Enterprise Trade and Employment promoted the export of Irish Peat to Africa without addressing legal status of extraction under the Environmental Impact Assessment and IPPC Directives, let alone sustainability. In 2010 the Department of Agriculture and Food published a ten year strategy ?Food Harvest 2020?. This includes an objective to increase milk production by 50%. No evaluation was carried out on the impact of this on climate emissions, biodiversity or fertilizer and energy use was not addressed. Ireland?s failure to adopt an integrated sustainable development model over the last 20 years has created unquantifiable, social, environmental and economic costs for the future. The cost of the EU/IMF bailout is only now being recognised. Parallel to this we face the social cost of poorly integrated socially divided communities, car dependence and obesity, poor planning in climate adaptation and flood risk. Our high dependence level on imported fossil fuel creates unquantifiable cost exposure in transport and energy. Poor biodiversity protection and water management will need significant remedy to meet EU standards and Directives. The failures of the last two decades cannot be reported. Sustainability needs legal and practical effect in all future planning and decision making. The key recommendation of this submission is the need to give sustainably legal effect in the Constitution and legislative remit of Government departments and State agencies and companies. An Taisce Tailors Hall Back Lane Dublin 8 Rio+20 United Nations Conference on Sustainable Development An Taisce Submission to the UN October 2011 1 SUSTAINABLE DEVELOPMENT 1.1 Introduction Much of the current national political and media focus is on promoting economic development and employment. While all mainstream commentators and politicians extol the virtues of a return to economic growth (GDP/GNP) as the conventional solution to our current economic, unemployment and fiscal difficulties it should be borne in mind that there is an inherent contradiction between the current model of economic growth and environmental and resource sustainability. Our society is currently locked into an economic system that has a GDP growth imperative and, as a consequence, increased energy demand, increased greenhouse gas emissions and increased resource throughput and depletion. Our ecological debts are as unstable as our financial debts. Neither is properly accounted for in the relentless pursuit of consumption growth. This contradiction is placing further pressure on the carrying capacity of the environment to support society and the economy. Furthermore, GDP economic growth is a highly imperfect and counter-productive measure of human progress as it only measures income and does not account for the consumption of natural capital (resources) or the significant costs of anthropogenic pollution. The Stern Report noted that Climate change is the greatest and widest-ranging market failure ever seen. As can be seen from the very high prices in Brent Crude Oil, the return of economic growth to the world economy has triggered an energy price spike, reducing consumption demand and further recession. Continued GDP economic growth in the Irish economy is unsustainable in the long-term and it is prudent to plan now for a different economic future including ?low growth? or ?no growth? scenarios. For example, a 2 per cent per annum growth in GDP would mean the carbon occasioned by each unit of economic output would have to be 130 times lower in 2050 than it is today otherwise we cross a threshold in terms of carbon emissions that future generations are unable to recover from. Economic growth is therefore inconsistent with the requirement to abate greenhouse gas emissions. In any event, 2% GDP growth would mean the total size of the Irish economy with double every 35 years. This is not physically possible in finite world and we should therefore not be planning for it. Current Government policy is to promote the Smart Economy and a return to an export-led economy. While this strategy has many virtues it is based on the premise that Ireland cannot compete with manufacturing industries in low-cost developing nations in a globalised economy. As a consequence, the structure of modern developed economies such as Ireland have typically tended to move progressively away from domestic manufacturing resulting in more and more finished and semi-finished goods need to be imported from abroad and expanding the financial and services sector to pay for it. Of course, this strategy is extremely vulnerable to oil price inflation (for transport) and outsources environmental degradation to less regulated countries. We submit that a strong local manufacturing base that is based on the sustainable use of local indigenous resources and local markets will make Ireland more resilient in long run. Current national economic development policies demonstrate a long-term blindness to the limitations of the material world. Responses to the crisis which aim to restore the status quo are misguided and doomed to failure. Prosperity today means nothing if it undermines the conditions upon which the prosperity of tomorrow depends. 1.2 Constitutional and legislative provision for sustainable development. The provision of Constitutional amendment to incorporate the revised and updated sustainable development declaration which will emerge from Rio +20 process. Legislative provision for sustainable development as an overarching objective, parallel to national climate change legislation with mandatory greenhouse gas emission reduction targets. Revision of remit of Government departments state and Statutory boards and Government share-hold controlled companies, including Bord Na Mona and Coillte with sustainable development as overriding objective. 1.3 Reducing Irelands global resource consumption and emission footprint. A range of global emission and resource consumption measurements now exist which all establish the unsustainability of continuing consumptions and emission levels. The 2006 National Footprint Network table (Appendix 1) is particularly striking in illustrating the disparity between the developed and the poorest countries. Global footprint calculation is based on a range of measurements including arable land use area, water use, fossil fuel and mineral resource use, calculating point of origin and transboundary impacts. The October 2010 Living Planet report identified Ireland as having the tenth highest global footprint The Living Planet report looks at the changing state of ecosystems, consumption of natural resources and the implications for the future of the world. Overall, the report concludes natural resources are being consumed faster than the Earth is replenishing them. People are now living lifestyles which would require one and a half planets to sustain, though there are significant differences between rich and poor nations. The report, carried out by the World Wildlife Fund, examines the number of ?global hectares? ? the amount of biologically productive land and water available per person on the planet ? that countries need. Irish people on average use just over six global hectares per person, more than double the demand of some EU countries, such as Hungary and Romania. The worst offender is the United Arab Emirates. Irish per capita resource consumption levels and global foot impacts are at a comparable level to the US and Australia. Post boom Ireland retains in high per capita levels of energy consumption, consumer and household goods and clothing, meat and processed food. 1.4 Transport 1.4.1 Shipping Greenhouse gas emissions from international shipping activity currently account for at least around 3% of total global emissions, and comparable to aviation. The global shipping and aviation sectors were not included in the failed Kyoto protocol, and left to be addressed in future agreements. The most recent study into medium to long-term traffic volumes at Irish ports is provided in the Dublin Port National Development Plan Study, published in 2009. This study took account of the economic downturn and the uncertainty over when the economy would return to growth. The Study concluded that the sector would face renewed capacity constraints from approximately 2025 onwards. This study did not factor the emission and resource consumption reductions that will be required by 2020 or the impact of oil production peak. 1.4.2 Low carbon sea-rail link from Dublin to London Ireland is unsustainably dependant on international air travel for connectivity. This creates high per capita levels of greenhouse gas emissions, and disproportionate risk exposure to future fluctuation in fossil fuel costs or natural events such as a major Icelandic volcanic eruption. A joint initiative will be negotiated with the UK Government and Welsh Assemblies for a low carbon Dublin-London link extending electrification of rail link from Crewe to Holyhead and procurement of the most emission efficient passenger ferry vessels. The impact of the spring 2010 Icelandic volcanic eruption highlighted the strategic importance of foot passenger services from Ireland to Britain and France. This was reinforced by the minor May 2011 eruption which curtailed the Barak Obama visit to Ireland. Based on the nearly 1,000 year historic data on Icelandic volcanic eruptions and older ice core data, there are future unpredictable risks, in duration and time interval for much larger scale eruptions such as occurred in the 1780s, which would be capable of curtailing jet aviation in Europe and the North Atlantic for unquantifiable time periods. It is unclear what future risk factor should be calculated for such an event, whether 1 in 100 years, 1 in 200 years or a larger margin. There are factors apart from volcanic ash risk, requiring that low carbon sea passenger connectivity should the single most important marine transport priority for Ireland in order to: 1. Ensure that aviation greenhouse gas emissions are reduced in tandem with all other categories of national and transnational emissions 2 .Avoid future exposure of aviation fuel to unpredicted price rise, which would create an unplanned flip to sea passenger demand. Existing passenger ferry services to Britain and France, are primarily car and roll on and roll off freight services. Ferries are poor in emission standards. There is a need for a new generation of low carbon efficient specifically passenger ferries, with the most efficient achievable land connection to London and other centres. This provides a major co operation opportunity to use the Cross Border and Ireland UK institutions under the Belfast agreement, to a real practical benefit. 1.4.3 National transport investment A time-tabled implementation of the targets set out in Department of Transport?s Smarter Travel Policy 2009 is required. Smarter Travel: A New Transport Policy for Ireland 2009 ? 2020 sets out a series of overriding policy objectives in Chapter 3, summarised as follows: 1 Future population employment growths will predominantly take place in sustainable compact forms which reduces the need to travel for employment and services; 2 500,000 more people will take alternative means to commute to work to the extent that the total share of car commuting will drop from 65% to 45%; 3 Alternatives such as walking, cycling and public transport will be supported and provided to the extent that these will rise to 55% of total commuter journeys to work; 4 The total kilometres travelled by the car fleet in 2020 will not increase significantly from current levels; 5 A reduction will be achieved on the 2005 figure for Greenhouse gas emissions from the transport sector. Local initiatives to reduce short car journeys in favour of walking or cycling. Regional and national initiatives to increase modal share of public transport through investment and traffic management using revenue from carbon tax and parking fees. National implementation of car parking levy in all commercial and other locations. This would in particular remove the unfair advantage of out of town urban fringe retail in comparison to town centre retail. Limiting of further world investment to minimal bypassing of towns and villages causing bottleneck/congestion. Abandonment further investment inter regional road inter regional motorway/dual carriageway schemes and cross border Dublin-Derry dual carriageway focusing of investment in Greater Dublin Area and other major urban centres on bus priority measures, bus rapid transport and investment in best technology, lower emission buses. 1.4.4 Rail freight and Smarter Travel Policy Successive transport ministries and CIE Iarnrod Eireann have pursued a deliberate policy of running down rail freight over the last 20 years, reflected in the closure of the Navan Kingscourt freight line in the early 1990s The Lisheen and Galmoy lead and zinc mines were ill advisedly permitted without requirement for a rail spur. The closure of the Navan Kingscourt freight line in the early 1990s Iarnarod Eireann failed to exploit the potential of Rosslare Port as a rail based freight hub and has now closed the vital strategic Waterford to Rosslare railway line representing a major strategic failure. In the overall exercise of its remit CIE Iarnarod Eireann has failed systemically to take leadership as a public transport provided The objectives on rail freight stated in Department of transport ?Smarter Travel? policy are vague and ineffective. Specific targets in increased of annual tonnage in rail freight is required. 1.5 Electricity generation and heating 1.5.1 Greenhouse Gas Power Generation Phased reduction of peat and coal for power generation at Moneypoint and 3 peat burning power stations which cessation achieved by 2020. 1.5.2 Domestic and other heating Ireland faces a particular challenge in reducing levels of greenhouse gas emissions in the domestic heating sector because of poor insulation quality of national housing stock, the higher levels of energy consumed in one-off houses or free standing houses and limited capacity in retrofitting district housing schemes. Up scaling of national energy refit/insulation programme using government bonds with householder loan scheme for ten year repayment period demonstrating net energy saving over payment of borrowings during this period. The priority is phasing out of domestic peat combustion from mechanised extraction sources by 2020 with incentivisation of energy insulation alternatives biomass or other renewable sources where appropriate. 1.5.3 40% Renewable energy target by 2020 Ireland faces major challenges in meeting the 2020 40% renewable energy target. This requires a strategic approach to grid enforcement and wind energy distribution while at the same time minimising impact on biodiversity peatlands and sensitive landscapes. 1.6 Tourism and outdoor recreation Strategies for promotion of tourism need to minimise aviation dependence because of risk to future cost of fossil fuel and exposure to natural events such as a significant Icelandic volcanic eruption (see section 3.2 under transport). Investment should focus on encouraging home tourism and recreational activity and maximising visitor numbers to Ireland by sea from Britain and continental Europe. Tourism investment should be linked with the protection and enhancement of the existing natural and cultural endowment. There are particular opportunities to develop Ireland as a focus for outdoor recreation and in particular walking/hiking, cycling/mountain biking, surfing, canoeing/kayaking. A number of significant initiatives have been taken such as the cycling/mountain bike trails developed by Coillte in Ballyhoura, County Limerick and the Dublin Mountains, the development of the Clew Bay cycle way between Westport and Mulranny and the major initiative in the promotion of canoeing/kayaking on the Northern Ireland Waterways. A key focus is the integration of a tourism investment with local communities and stake holders with parallel benefit in maximising local employment and dispersal of economic input from visitors across a wide spectrum of the community. 2 BIODIVERSTIY One of the major agreements at Rio 1992 was the Convention on Biological Diversity. The Convention established three main goals; (1) the conservation of biological diversity, (2) the sustainable use of its components, and (3) the fair and equitable sharing of the benefits from the use of genetic resources. Ireland along with other signatories submits reports on their achievements under these headings. However, An Taisce has a number of concerns about Ireland?s efforts to attain these goals and has illustrated some examples under each of the three headings. 2.1 The Conservation of Biological Diversity. 2.1.1 Protected areas. Special protection Areas for Birds (SPAs) and Special Areas of Conservation (SAC?s). Irelands SPAs and SAC?s are designated and protected by the European Birds Directive and the European Habitats Directive respectively as part of the Natura 2000 network established by the European Union in response to the Convention on Biological Diversity. As such, full implementation of EU legislation is seen as integral to Ireland fulfilling its obligations under the Convention of Biological Diversity. Ireland has the lowest percentage of land protected by SPA?s of all EU states bar Malta, though additional areas are being proposed and this is welcomed. However many difficulties exist, with rulings found against Ireland by the European Court of Justice (ECJ) in areas such as, correct designations, failure to correctly transpose important provisions of the Birds Directive and the Habitats Directive, protection of designated sites from pollution and deterioration, etc. All of these failures are in the context of continuing declines in the conservation status of important protected habitats and species. Just over 93% of Ireland's Annex 1 habitats under the Habitats Directive have either a poor or bad conservation status. Many habitat types are classified as being in overall ?unfavourable ?bad? status. Favourable reference values are the minimum values required for the long term survival of the habitat or species. NPWS and Funding The National Parks and Wildlife Service (NPWS) is currently preparing Site Management plans for SAC?s and Species Action Plans (SAPs) for species of highest conservation concern. A number are already published, which is welcomed. However, the further compiling of management plans and implementation of existing management plans depends largely on the resources available to the NPWS (as well as the extent to which other government departments take on their responsibilities in relation to Natura 2000 site management and protection and their own areas of responsibility, such as planning, forest licensing, and agri-environment support measures). The 2011 budget cuts for the Department of the Environment Heritage and Local Government were entirely disproportionate in comparison to those for Tourism, Arts and Sport. Particularly significant was the 57% cut in the ?project? funding of the NPWS and 47% cut in the budget of the Heritage Council. This trend of underfunding nature conservation in Ireland needs to be reversed if Ireland is to conserve its biological diversity in line with the EU 2020 biodiversity strategy. This strategy in turn responds to the global Strategic Plan for biodiversity 2011-20207 agreed at the Conference of the Parties (CoP10) to the Convention on Biological Diversity. Following the last governmental election the NPWS were transferred from the former Department of the Environment Heritage and Local Government to the Department of Arts, Heritage and Gaeltacht. This switching around of Heritage between Departments is something which has happened on a frequent basis following General elections. It swallows valuable resources the reorganisation of Human Resources, Accounting and Communications systems, the design of new websites and new stationery and the disruption of working relationships cost a lot in terms of money and time resources. Cumulative impacts and transparency An Taisce conducted an investigation into two randomly selected SAC?s to attempt to assess the procedure from site selection designation right through to ongoing site protection. One example which illustrates the lack of assessment for cumulative impacts was highlighted in connection with the Forestry Service. All forestry files, for the period of January 2007 to June 2010 in relation to the two SAC?s were requested. The Forest Service stated the request was too ?voluminous?, they also stated that ?we do not have data stored on an SAC basis? and requested a fee of ?3,854.80 in order search and retrieve the files requested. After An Taisce requested an internal review of this decision it was upheld by the Forest Service. Currently the request is being appealed to the Commissioner for Environmental Information. This indicates that currently afforestation licences in SAC?s are being assessed on an individual basis. That the information is not accessible for Forest Service staff in going about their duties seriously compromises their ability to assess potential impacts including cumulative impacts upon designated areas. This deficiency needs to be rectified as it is vital that all sites protected under EU and Irish Environmental Legislation are easily identified by Forest Service staff and easily accessible to the general public, stakeholders and NGO?s. In reality SAC management falls under many different organisations. It is not just the NPWS that is responsible for the conservation interests of a site. The roles of organisations outside the control of the NPWS can influence the conservation status of an SAC. Therefore, responsibility also falls to the Department of Environment, Community and Local Government (DoECLG), DAFF, the Forest Service, Planning authorities (county councils), Inland Fisheries Ireland, etc. A mechanism is needed for developments such as windfarms, strategic infrastructure, forestry, aquaculture, etc to be assessed by different agencies and authorities in a specific area. Salmonoid rivers In 2005 SAC Rivers throughout Ireland had changes made to the boundaries of the buffer zone required between SAC Rivers and areas outside the SAC from previous levels of 50 ? 20m down to 2.5m including all salmonid rivers. Revising the boundary to a 2.5m buffer zone increases the danger of run-off from agricultural fields getting into the river system. An Taisce considers this change in the law was a retrogressive act which may reduce the conservation status of Ireland?s rivers. The possible ramifications for water quality are many fold, one example being the status of protected species such as salmon Salmo salar, lamprey Lampetra planeri, crayfish Austropotamobius pallipes etc Natural Heritage Areas (NHA?s) and proposed Natural Heritage Areas (pNHA?s) NHA?s are areas that contain flora and fauna, habitats, or geological or geomorphological features which are of interest for their diversity of natural attributes, and which are thus worthy of conservation. These areas are protected under the Wildlife (Amendment) Act of 2000. Currently, only bog NHAs have been granted statutory protection. There are a further 617 pNHAs which still do not have the full legal protection they require although have been proposed since 1995. Many conservation professionals are alarmed by the unchecked destruction of pNHAs across the country. Protecting NHAs with statutorily awarded NHA Orders is crucial to strengthen the coherence and benefits of Ireland?s network of ecosystems and ?Green Infrastructure?; to protect the functional values and ecosystem services of Ireland?s Environment; to buffer against the impacts of Climate Change; to deliver commitments under European Nature Directives; and a worthy task toward achieving Ireland?s objectives under Sustainable Development objectives and the EU 2020 biodiversity strategy. Actions required for protected areas ? Complete the designation and protection of Natura 2000 sites in immediate future. ? Set site specific conservation objectives for all Natura 2000 sites by 2012. This obligation is long overdue and needs to be allocated necessary resources and prioritised without further delay. The creation of site specific management plans for all Natura 2000 site would also be welcomed. ? Address the serious problems that exist around planning policy and the effective management of protected areas in Ireland. An Taisce recommend that binding statutory guidelines are produced (with associated training) for Local Authorities and other planning bodies on the protection of species and habitats listed in the Annexes of the Habitats and Birds Directives in order to ensure compliance with the Directives and maintain Favourable Conservation Status of all protected species and habitats. ? Proceed with the designation of pNHA?s starting with those which do not need further surveys as identified by An Taisce report NHAs The Case for Conservation. 2.1.2 Wider countryside Biodiversity Forum Comhar (the Sustainable Development Council) has been abolished and its remit taken over by the National Economic and Social Council (NESC). The Biodiversity Forum as it existed under Comhar was essential to ensure stakeholder involvement in drawing up and implementing the National Biodiversity Plan as required by each country under the Convention for Biological Diversity. No mention has been made to the continuation of the Biodiversity Forum. An Taisce sees this as a step backwards in fulfilling our obligations under the Convention for Biological Diversity. Actions required for the wider countryside ? The Biodiversity Forum should be reestablished as a matter of urgency. ? Urgent action is required as regards habitat mapping for Ireland. ? A National Hedgerow Conservation Plan for Ireland should be realized. ? It is imperative that each Local Authority has a designated biodiversity officer to undertake natural heritage conservation responsibilities. ? More specific actions for forestry are needed. 2.1.3 Transposing EU Directives The introduction of primary legislation is required to ensure affective transposition of EU Directives on Waste, Water, Air, EIA, IPPC, Birds and Habitats. Excessive use of S.I.?s and regulatory amendments undermines the implementation of effective transposition (see example on EIA assessment below). Where functions are delegates to local authorities the EPA or other statutory body?s adequate national oversight is required on implementations. Environmental Impact Assessment (EIA) assessment - Split authorities A European Court of Justice (ECJ) judgment found that Ireland did not take enough account of sensitive countryside features. The judgment found that the thresholds for undertaking an EIA for certain types of projects, including the restructuring of rural landholdings and water management projects land drainage, were based on high size thresholds alone. Ireland has recently sought to address this with two pieces of recent legislation. However, in seeking to address this judgment on EIA Directive, compliance in another case should have been addressed. This case related to the lack of proper provision for consent authorities in Ireland to perform EIA, and the issue of lack of integrated assessment in the case of split jurisdictions for consent on different elements of a project. While the case cited the split between planning legislation and EPA functions for EIA, the judgment is applicable to all split consents. These proposed Department of Agriculture, Forestry and Fisheries (DAFF) Regulations follow SI No 456 of 2011 which creates a new EIA threshold, screening and assessment and consent regime under DAFF. This establishes a new EIA consent function at a time when another case has highlighted the lack of integration between existing EIA consent functions in Ireland. Giving this decision making power to the Minister for Agriculture, Fisheries and Food is contrary to current practice which is to vest such decision-making power in independent decision making bodies. For example, the Minister for the Environment, Community and Local Government?s power to grant foreshore licenses is to be transferred to planning authorities and An Bord Pleanála. Actions required for the EU Directives ? Primary legislation should be used to ensure affective transposition of EU Directives. ? All decision-making powers in relation to Environmental Impact Assessment should be given to independent decision making bodies. ? All plans and strategies should be proofed against existing legislation to insure they do not contravene them. 2.2 Sustainable use of the components of biodiversity, All human activities, including all our economic activities, take place inside, and cannot exceed, the carrying capacity of our environment. The carrying capacity of our environment is dependent on the healthy functioning of our biodiversity and ecosystems. From an economic perspective, numerous attempts have been made to understand the value of biodiversity to humanity in terms of ecological goods and services for instance insect pollination, water regulation and purification, carbon storage. The Millennium Ecosystem Assessment (MA) assessed the condition of 24 of the earth?s natural systems that it considers humanity?s ?life support systems?. It concluded that over the previous 50 years, four of these systems have shown some improvement, fifteen are in serious decline, and five are in a stable state on a worldwide basis, but threatened in some parts of the world. The establishment of the TEEB (The Economics of Ecosystems and Biodiversity) study (http://www.teebweb.org/) is another initiative to highlight economic benefits of biodiversity, cost of biodiversity loss and ecosystem degradation, and make practical management recommendations. Yet other reasons to conserve biodiversity are equally valid and must not be lost in the rush to weigh up its economic value to humans. There is also our ethical responsibility to conserve biodiversity and facilitate a shift toward societal respect for nature. In the words of Richard Frankham ?The ethical justifications for conserving biodiversity are simply that one species on Earth does not have the right to drive others to extinction, analogous to abhorrence of genocide among human population?. Pollination The value of crop pollination in Ireland by all pollinating insects has been estimated as ?53million per year in Ireland. Unfortunately, the current status of Irish pollinators appears to be in decline, with 30% of the wild bees and 18% of butterfly species in Ireland considered threatened according to the International Union for Conservation (IUCN). Soil Protection To achieve food security in face of an ever growing population, Ireland and the world, will require large areas of fertile land. However increasing pressures such as urbanisation, afforestation, industry, erosion and overgrazing are putting soil quality at risk. As yet there is no program to monitor and protect this essential resource in Ireland. In the European Union it has been estimated that soil deterioration costs 38 billion a year, however to date; no such figure appears available for Ireland. Flooding With a predicted rainfall increases of 17% in western areas of Ireland and possibly as much as 25% in places, the importance of adequate flood management is immediate. An Taisce commissioned a report ?The Use of Wetlands for Flood Attenuation? which highlights amongst other issues the draining of many small wetlands. ?Small isolated wetlands, or ?kettle holes? within a landscape probably have limited storage capacity and flood attenuation potential on an individual basis, but studies show that when many small wetlands occur within a catchment, the aggregate storage capacity may give rise to considerable flood attenuation potential.? Actions required to protect Ecosystem Services. ? Stricter protection of the wider countryside utilising the natural buffer zones provided by biodiversity in relation to pollination, flooding mitigation etc. ? Future strategies for Flood Risk Management should refer to increasing research into the services of wetlands in flood attenuation and the incorporation of wetland protection and management into flood risk management plans. ? A National Hedgerow Conservation Plan for Ireland should be realised. ? Prioritisation of a national action plan on Green Public procurement (the importation of illegally felled timber being a particularly significant issue); and detailed actions for ensuring legal protection of Irelands Natural Heritage Areas. 2.3 Sharing the benefits arising from the commercial and other utilization of genetic resources in a fair and equitable way Ireland has not yet signed the Nagoya protocol to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization (ABS) to the Convention on Biological Diversity which is a supplementary agreement to the Convention on Biological Diversity. Action to be taken This treaty should be signed without delay. Other issues. Aarhus Ireland has not ratified Aarhus. Action to be taken This treaty should be ratified without delay. Summary An Taisce believes that the principle outcomes of Rio+20 should include: ? A recommitment to fully implement those principles of the Earth Summit 1992 which have not yet been completed, both nationally and internationally. ? To prioritize those principles that have become even more critical, namely biodiversity and habitat loss, measures to counteract Climate Change, eradication of poverty, greater emphasis on Local Agenda 21 and 'bottom up' sustainability measures. ? A firm principle on strong governance and oversight to ensure audit and implementation of the measures agreed. APPENDIX I This document is written in an Irish context but with universal analysis. PRICING CARBON AND RESOURCE CONSUMPTION IN GLOBAL TRADE. The 2007 Stern report identifies the climate change as the greatest ever market failure. Global trade is operating to a short term economic model which disregards the immediate and longer term impact of climate emissions. The worlds? poorest in Sub Saharan Africa are already victims. Rich high resource consuming countries have externalised their real emission impact on other countries. One third of total Chinese emissions or half the increase over the last decade is for the manufacture of goods for the developed world, in factory conditions that would not be remotely tolerated in the West. China is becoming a progressively larger extractor of global resources including mineral smelting and extraction in Africa (2009 Carnegie Mellon University). The up scaling of shipping to develop container vessels the size of oil tankers has made long distance transport such a small element in the cost of global consumer goods and has enabled this mass production of goods from the energy of coal burning power stations of China. Port expansion and the accommodation of larger tonnages of container ships and throughputs directly increases global Greenhouse gas generation in shipping and the manufacture of consumer goods, many of them throw away with a short performance life, leading to unsustainable waste streams. Future global and national trade models require the full internalisation of the cost of carbon emission generation and resource consumption. This requires that cost must be borne by the end use consumer, and be at a level that a per capita emission level which climate science requires cannot be exceeded. The imperative of containing nuclear radiation levels within accepted safe levels, must be applied equally to climate emissions. It is no coincidence that the emergence of this recent enlightenment on the importance of issues associated with sustainable development has coincided with the national economic collapse and the inter-related major challenges of peak oil, climate change, resource scarcity and the persistent degradation of our natural environment and its ecosystem services. There is now a general overwhelming international and national consensus amongst policy makers at all levels of the policy making hierarchy that business as usual is no longer an option, we can no longer afford to continue the pursuit of the failed short-sighted policy approaches of the past and that our collective future must be different. The international and national economic recession has provided a narrow window of opportunity to take action to concentrate investment and focus policy on the transition to a post-oil low-carbon locally resilient society. This is the major challenge of our time and will require urgent understanding of the nature of the challenges; no shortage of decisive political leadership, a radical change of direction together with robust and, in some instances, policy implementation which will be politically unpopular in the short-term. Through the regulation of port capacity, Dublin Port Company, has the most critical role to play in facilitating this transition. ENERGY DESCENT & CLIMATE CHANGE ? THE CHALLENGE Peak oil and climate change are the interrelated biggest challenges of our time. We are currently experiencing an environmental and resource crisis that places human development at a crossroads. The implications of climate change, peak oil and resource scarcity are becoming increasingly visible and are being exacerbated by economic recession. The effects of these challenges are, and will continue to be, multi-faceted and systemic. Effects include energy price inflation, increased flooding; increases in the cost of resource dependent production; food shortages and other scarcities. These challenges, and the necessary development of policies to address them, are becoming a reality with which society has to learn to live by becoming more localised and resilient. It is likely that energy price inflation and climate change will also have additional crippling effects on our economy. The 2007 Stern Report, for example, strongly suggests that climate change will result in an average 5-10% loss in global GDP. In addition, protection against flooding and the clean-up costs after extreme weather incidents will place significant burdens on our national finances. The total cost of the major 2009 floods in Ireland was estimated to be ?244m (Irish Insurance Federation, 2010). The rising cost of insurance due to the increased risks posed by climate change will also have major implications especially for those on low incomes. In 2010, the Irish Brokers Association stated that Irish homeowners will face insurance premium increases of up 20% due to flooding (Irish Times, 26/2/2010). Greenhouse Gas Emission Reduction Targets As discussed above the Planning & Development (Amendment) Act 2010 includes a new mandatory objective as follows: ?The promotion of sustainable settlement and transportation strategies in urban and rural areas including the promotion of measures to (i) reduce energy demand in response to the likelihood of increases in energy and other costs due to long-term decline in non-renewable resources, (ii) reduce anthropogenic greenhouse gas emissions, and (iii) address the necessity of adaptation to climate change in particular, having regard to location, layout and design of new development.? Circular (PSSP-4-2010) issued to all Planning Authorities and has determined that the following national policy documents relate to proper planning and sustainable development under section 9(6): a) Smarter Travel ? A Sustainable Transport Future: A New Transport Policy for Ireland 2009 ? 2012 (Department of Transport) b) National Climate Change Strategy 2007 ? 2012 (Department of the Environment, Heritage and Local Government). The Government has signed up to the 20:20:20 EU agreement whereby we have a legally binding pledge to reduce greenhouse gas emissions by 20% below 1990 levels and increase energy efficiency by 20% by 2020. The scale of change needed to meet Ireland?s commitments is enormous. Ireland?s national Green House Gas (GHG) emissions reduction target equates to c.2.5% per year until 2020. Greenhouse gas emissions from the transport sector have risen 170% over 1990 levels primarily due to spatial sprawl. Oil Dependency Peak oil is a monumental challenge, the impact of which is widely and significantly underestimated, misunderstood and eschewed by official policy makers. Ireland is the seventh most oil dependent economy in the world (O?Neill, 2003). Ireland?s primary energy usage increased by 67% between 1990 and 2006 (SEAI, 2008). Further, demand for fossil fuels is increasing, not decreasing. Ireland is 99% dependent on oil for transport and is amongst the most private car dependent countries in the world. Ireland is also highly dependent on road haulage for freight with only an extremely marginal rail freight infrastructure. The amount of oil used for transportation in Ireland tripled between 1972 and 2002, leaving Ireland consuming at least 50 per cent more per capita than the average of the EU-25 by the end of the period. There is growing international consensus, as expressed by Macquarie Bank, Goldman Sachs, McKinsey Consultants, the UK Industry Task Force on Peak Oil and Energy Security, the UK Energy Research Council, IHS Herold, OFGEM, ASPO, Global Witness, the International Energy Agency and the Saudi Oil Ministry together with, most recently, Lloyds Bank that the ?era of cheap oil is over? and that serious supply constraints and an oil supply crunch is likely in the short-to-medium term. The Hirsch Report commissioned by the US Department of Energy in 2005 highlights very clearly that the era of plentiful, low-cost petroleum is approaching an end. World demand for oil is predicted to increase by 50% over the period up to 2025 at a time when the world oil reserves are diminishing rapidly and will lead to rapid price inflation and scarcity. The key issue with peak oil is that it is not an energy crisis so much as a 'liquid fuels' crisis, which will have immediate consequences for the main categories of oil usage, in particular transportation. As Ireland is particularly and increasingly dependent on oil for transportation, we are particularly vulnerable to oil price inflation it is important to start preparing and contingency planning for such an event. The Hirsch Report states: ?The peaking of world oil production presents the U.S. and the world with an unprecedented risk management problem. As peaking is approached, liquid fuel prices and price volatility will increase dramatically, and, without timely mitigation, the economic, social, and political costs will be unprecedented. Viable mitigation options exist on both the supply and demand sides, but to have substantial impact, they must be initiated more than a decade in advance of peaking.? More recently, the International Energy Agency - World Energy Outlook published in November 2009 and again in November 2010 confirmed that oil prices are likely to inflate significantly through to 2030 and the continuation of current energy use trends would have dire consequences for climate change together with huge systemic implications for the economy, society and environment. They would also exacerbate ambient air quality concerns, thus causing serious public health and environmental effects, particularly in developing countries. The current economic recession is likely to further exacerbate oil price inflation due to lack of current investment in boosting capacity. We would respectfully refer to the following critical reports, which should be foremost in the consideration in the preparation of the Development Plans: A Baseline Assessment of Irelands Oil Dependence - Key Policy Considerations, Forfas, 2006 Tipping Point: Near Term Systemic Implications of a Peak in Global Oil Production: An Outline Review; Feasta, 2010 Sustainable Energy Security ? Strategic Risks and Opportunities for Business (White Paper), Lloyds/Chatham House, 2010 Growth Isn?t Possible ? Why We Need A New Economic Direction, New Economics Foundation/Schumacker College, 2010 As confirmed in the Hirsch Report there is no ready alternative to oil for private vehicle use. In this context, debates over substituting oil with renewables are irrelevant. The widespread replacement of the current vehicle stock with electric powered vehicles is economically and environmentally impractical. The mass production of battery or hydrogen technology capable of the propulsion of electric vehicles, particularly HGVs, is at the very least several decades off and it is most probable that there is no technological solution to this problem. The preferred raw material for the production of batteries, Lithium, is itself severely resource constrained and found largely in highly politically unstable regions of the world. In any event, the mass production of electric vehicles is wholly resource inefficient and the use of increasingly scarce energy for unproductive uses, such as electric vehicles, would be imprudent. Bio-fuels are not a solution as it competes with food for land and drives up food prices. For example, the grain required to fill the tank of a modern car could feed one person for a year. Accordingly, any rational analysis of future available oil resources and energy resources would result in an inevitable conclusion that further public investment in new air transport infrastructure or road transport infrastructure for use primarily by private vehicles is short-sighted, ill-conceived and an inefficient use of public funds. While we recognise that there remains a considerable straightforward connection in the minds of policy makers and elected members as to the economic benefits of road infrastructure, the overwhelming international evidence clearly indicates that past trends must not be used as a guide to likely future outcomes. Further investment in Ireland in road infrastructure (outside of road infrastructure maintenance) and the shaping of our society and economy around oil based transport (i.e dispersed settlement patterns) will inevitably increase and ?lock-in? our exposure to oil price inflation and undermine the resilience of our economy and society in an era of peak oil and our international greenhouse gas reduction commitments. -3 w Route Selection Study for a City By-Pass for Oil Vulnerability & Carbon Price Impact Assessment As compared to other northern European countries Ireland is considered to have significant infrastructural deficits that undermine our national competiveness particularly in transport and waste infrastructure. The former is largely a result of our laissez faire and malleable land-use regulation and permissive approach to market-driven car dependent dispersed development patterns that were not aligned with appropriate infrastructure investment. The latter is as a consequence of a complete absence of any understanding of environmental carrying capacity and the short-term prioritisation of new development over other public health and environmental interests. The Capital Investment Programme 2010 - 2016, Transport 21 ? much of it dependant on PPP?s has collapsed leaving major public transport deficiency. The Water Services Investment Programme is designed for a now departed era of energy abundance with no consideration given to the future price of oil or carbon. For example, the current energy bill for a large modern waste water treatment plan can be in the order of ?2.5 million per annum. No assessment is being undertaken to ascertain whether this huge Exchequer investment is entrenching deep structural vulnerabilities in our society and storing up major problems for the future. Peak Oil and its impacts is a phenomenon which is we cannot avoid but we should urgently prepare a risk management strategy for its effects. A permanent oil shock is coming and is the biggest threat to Ireland?s economy and society. A national ?Oil Vulnerability & Carbon Price Impact Assessment? is required to assess the threats to our future from inflated and volatile oil prices together with the future (shadow) price of carbon. This should be undertaken for both capital and operational municipal functions (e.g. sewage treatment, water supply, road developments, road repair, flood defences etc) and of vulnerabilities to the general economy (e.g. increased distribution costs, decline in tourism, retail etc.). 1. BUILDING IREALNDS SMART ECONOMY 2008 2. The 2008 developing Ireland's Smart economy does not identify high tonnage or bulky exports as a part of the future smart economy. 3. INDUSTRIAL DEVELOPMENT AUTHORITY INWARD INVESTMENT STRATEGY 4. The main industries targeted by the IDA for future development are not dependent on high tonnage capacity. The high exports values generated by Irelands inward investment boom by multi nationals is in medical devices pharmaceuticals and IT services with a high value to tonnage ratio. 5. DEPARTMENT OF AGRICULTURE, FISHERIES AND FOOD POLICY 2020 FOOD HARVEST 6. The 2010 Department of Agriculture, Fisheries and Food 2020 Food Harvest policy was published without Strategic Environmental Assessment (SEA) . The application of SEA and other sustainability considerations means that significant additional export tonnage capacity will not be achievable. Future food security planning will require a significant reduction in current Irish import levels and dependence on fertiliser, grain, animal feed, fruit vegetables and processed foods. All parts of Irish trade need to be subject to sustainability evaluation. A prime example is the continued government promotion of peat compost export to UK, Europe and Africa, which is coming from illegal extracting sites in Ireland, and failure to screen sources of tropical hardwood import and wood products. An Taisce submits there is no requirement for additional oil or coal import capacity, since current levels need to be substantially reduced to meet climate emission reduction levels required and reduce unsustainable energy import dependency. The requirement to explore the percentage contribution of truly renewable gas as an important element of our energy solution also needs to be addressed. The London-based New Economic Foundation (NEF) has carried out considerable work in this area on the UK and accordingly, there is useful guidance in carrying out similar analysis in Ireland. This includes perverse trade for example in foodstuffs where goods of virtually identical type or quality e.g. are exported and imported in similar quantities eg plastic bottled water. In 2007 the NEF published Chinadependence, which remains equally applicable to the sustainability of Ireland?s trade relationship with the world at large (appendix 1) An Taisce submits that fully transparent information is needed on the nature origin and destination of all goods passing through Irish ports. The suggestion on pages 13 and 14 of the Departments consultation document that ?commercial confidentiality? applies is not tenable. The provision of the EU Access to Information on the Environment Directive 2003/4/EC and Arhaus Convention for which Irish ratification is overdue, require this.