I have written to the Minister for Transport, Tourism and Sport in relation to the draft Greater Dublin Area Transport Strategy. The Strategy was drawn up in order to address congestion and addressing climate change was not one of the objectives in developing the Strategy. This is contrary to the obligations which all public bodies now have under the Climate Action and Low Carbon Development Bill. I pointed this out in my response to the public consultation in relation to the Strategy, but the Strategy has now been sent to the Minister essentially unchanged. This latest draft was supplied to the Eastern and Midland Regional Assembly for our comments. My email of 9th January to Minister Donohoe (attaching my response to the consultation) is below.
Department of Transport, Tourism and Sport,
44 Kildare Street,
Re: Compliance with Climate Action and Low Carbon Development Act 2015 in the development of and adoption of a Transport Strategy for the Greater Dublin Area.
Dear Minister Donohoe,
I refer to the draft Transport Strategy for the Greater Dublin Area 2016 to 2035 which has been sent to your office by the National Transport Authority.The purpose of my letter is to draw your attention to the obligations which now apply to you and all other relevant bodies under section 15 of the Climate Action and Low Carbon Development Act 2015 and to highlight the relevance of these obligations to the adoption of a Transport Strategy.
The draft Transport Strategy which has been submitted to you envisages a significant increase in greenhouse gas emissions from transport in the Dublin area during more than half of the time period specified in the Act for transition to a low carbon, climate resilient and environmentally sustainable economy. As documented in the accompanying documentation, the strategy would lead to a minimal reduction compared to a ‘business as usual’ scenario.
The reason the Strategy has this minimal effect is that, as confirmed to me by the National Transport Authority (NTA), greenhouse gas emissions abatement was not one of the objectives which drove the development of the Strategy.
I pointed out in my submission to the NTA in response to their public consultation on the draft Strategy that, on the enactment of the Climate Action and Low Carbon Development Act 2015, adoption of the strategy as drafted would be illegal due to its failure to comply with the obligations in s.15 of the Act. From my reading of the subsequent draft submitted to you, my observation seems not to have been taken account of. I attach a copy of that submission for your information.
Manifestly, it would not be lawful for you to approve the draft Strategy without fundamental alterations aimed at bringing transport in Dublin in line with transition to a low carbon climate resilient and environmentally sustainable economy.
I am at your disposal to clarify any of the above or anything in the attached and hope to hear how you will comply with the Climate Action and Low Carbon Development Act.
Cllr. David Healy
54, Páirc Éabhóra,