Developing Resilience to Climate Change in the Irish Transport Sector November 2017

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1 Public Consultation Submissions Report Developing Resilience to Climate Change in the Irish Transport Sector November 2017

2 Executive Summary Developing Resilience to Climate Change in the Irish Transport Sector was published for public consultation on 28 December The deadline for receipt of submissions was 9 th February Some 10 responses were received from a wide range of stakeholders and interested parties. Those respondents who participated in the consultation process demonstrated significant engagement, understanding and concern for the policy under development and the various issues arising. This was reflected in the comments and feedback that were received, which were both constructive and insightful. A response to these contributions is set out in this paper under the following headings: Policy Integration & Cross-Sectoral Working Data Collection & Assessment Economic Investment Other Themes Responses to the issues raised in the consultation process: The submissions received as part of the consultation process have been comprehensively reviewed and careful consideration has been given to the issues raised. A number of themes emerged from the submissions. Changes have been made to the Plan as part of ongoing development around the area of climate change adaptation and the feedback received from this public consultation has been taken into account. These changes are discussed under Section 3.

3 Contents 1. Background 2. Acknowledgement 3. Summary Information on Submissions and Responses to Issues Raised Annex A: List of Organisations Annex B: List of Individuals

4 1. Background On 28 December 2016, the Department of Transport, Tourism and Sport invited submissions from stakeholders, interested parties and members of the public on the draft document Developing Resilience to Climate Change in the Irish Transport Sector along with the associated Appropriate Assessment (AA) Screening Report. Developing Resilience to Climate Change in the Irish Transport Sector is a Plan to develop a Climate Change Adaptation approach for the transport sector in Ireland. Climate Change Adaptation refers to how we plan for the negative effects of climate change and take suitable action to prevent or minimise damage it causes. Adaptation to the effects of climate change requires action to both manage the risks and to make adjustments to reduce our vulnerabilities. It is an essential component of our long term, strategic economic planning. The Adaptation Plan was prepared as part of the National Climate Change Adaptation Framework, 2012 (NCCAF), developed by the Environmental Protection Agency (EPA) in line with EU guidelines, as well as the provisions of the Climate Action and Low Carbon Development Act, 2015 The Plan focuses on assessing vulnerability to key climate variables and their likely impacts on our transport system and considers five key transport sub-sectors: road, rail, bus, aviation and ports. 2. Acknowledgement DTTAS wishes to thank those who took the time to respond to the call for comments on Developing Resilience to Climate Change in the Irish Transport Sector. All contributions will help to inform and enhance transport adaptation policy development. 3. Summary Information on Submissions and Responses to Issues Raised There were a total of ten consultation submissions; six received on behalf of organisations and four from private individuals. One submission was received after the closing date of 9 February but was taken into account in any case. Respondents included Government agencies/authorities, academia and other interested parties. 1

5 Main Themes Policy Integration & Cross-Sectoral Working Data Collection & Assessment Economic Investment Other Themes Air/Water Quality & Biodiversity Preservation Active & Urban Transport Policy Development Emergency Planning Public Health Main Submission Themes 1. Policy Integration & Cross-Sectoral Working A substantial theme in the comments submitted concerned the integration of the actions outlined in the Plan with measures highlighted in other sectoral, national and EU plans and policies. In general, there was consensus that the Plan should include information on proposed actions with timeframes and bodies responsible. The establishment of a sub-group to co-ordinate implementation of the Plan s actions was also proposed. One contribution suggested that the Plan should include specific proposals to initiate and sustain dialogues addressing cross-sectoral interdependencies and cross-cutting issues. Another submission suggested that the revised Plan should highlight the implications of climate change at community level. The inclusion of OPW CFRAM maps featuring areas most at risk would be instrumental in communicating the need for climate change adaptation. Finally, one contributor felt that the Plan should clearly outline its position in the hierarchy of national and sectoral plans for climate change adaptation. Response: This first Adaptation Plan represents an early stage in adaptation planning. A suite of short-to-medium-term measures has now been reflected in the Plan, which constitutes DTTAS next steps towards climate proofing the transport sector. DTTAS recognises that transport is central to the overall resilience of many sectors. Weather events are unlikely to affect one sector in isolation so it is important that 2

6 interdependencies between sectors are reflected in our policy thinking to ensure that climate change is mainstreamed into all general policy and strategic objectives to DTTAS will continue to cultivate interdependent working relationships with other sectors, local authorities, industry stakeholders and academic experts currently involved in developing climate adaptation measures. Such collaboration between sectors will help to secure a cohesive approach to a multi-layered adaptive strategy for Ireland. DTTAS will assist in the production of a sectoral adaptation guidelines document that will provide a valuable template for other Departments in the development of their respective adaptation plans. DTTAS will also participate in a cross-sectoral adaptation governance group to co-ordinate the implementation of various sectoral adaptation plans at a national level. As in the SEA, a graph illustrating where the National Adaptation Plan fits in the hierarchy of national and sectoral plans will be included in the body of the Plan. 2. Data Collection & Assessment The need to develop adaptation policy based on the collection and assessment of reliable data was a common theme in some four submissions. While most submissions were in broad support of the need to implement climate adaptation measures, one respondent was of the view that any future infrastructural investment should not be based on hypothetical risks. Another contribution highlighted the importance of continued climate research over a range of temporal and spatial scales to produce consistent climate data and analysis. Cross-sector transport modelling was given as an example of such research. Two submissions called for consideration of the monitoring, review and evaluation aspect of the Plan, calling for specific actions to be enumerated and their implementation and review quantified. Concerns were expressed by one respondent that the most up-to-date environmental baseline data should be incorporated into the Plan, questioning in particular the use of data from the 2013 IPCC Fifth Assessment Report. Response: In line with global trends, Ireland s climate is changing and the scientific consensus is that further changes are on the way. Incremental changes in climate are already evident in Ireland including changes in our average temperature, rainfall intensity and patters. While doubts remain in relation to both the rate and extent of climate change impacts that Ireland will experience we can be confident that over the coming years, climate change will affect many sectors of our economy and society. The impacts are uncertain but concerted action is required to prepare and deal with these changes. 3

7 DTTAS commits to ensuring that the climate data upon which the development of policy is drawn from current scientific understanding of climate change. The IPCC Fifth Assessment Report 2013 which has been referenced in the Plan is the most recent report from the IPCC. The Report offers evidence of climate change based on many independent scientific analyses from observations of the climate system, paleoclimate archives, theoretical studies of climate processes and simulations using climate models. The Sixth Assessment Report is currently in development and due to be completed in On completion, it will be referenced accordingly in future plans and policies. As part of the National Climate Change Adaptation Framework, the Department of Communications, Climate Action and Environment (DCCAE) is continuing to build the evidence base and tools to help understand and adapt to climate change. A number of tools have been designed specifically for Ireland and are available on the platform Climate Ireland. This site aims to provide guidance to identify the impacts of climate change and minimise the associated risks and/or exploit opportunities. In relation to supporting climate research and the development of climate modelling, DTTAS is currently engaged with academic experts via CIVIC (Critical Infrastructure Vulnerability to Climate Change), a project funded by the Environmental Protection Agency, with a view to informing our on-going climate change adaptation policy at a national level. The project will aim to address the knowledge gap for a key element of Ireland s critical infrastructure through highlevel assessment and detailed probabilistic modelling. It also aims to use stakeholder-led research to increase resilience to climate change at the critical infrastructure owner/manager level. We will also be supporting collaborative and sector specific research across the stakeholders group by engaging expert speakers, disseminating information on new technologies etc. 1. Economic Investment Two contributions made reference to the potential impacts of adaptation measures on economic investment. One respondent suggested that a cost/benefit assessment of adaptation actions, to include maintenance of existing transport networks and infrastructure, should be addressed within the Plan. In this context, the development of a stocktake of transport infrastructures and a framework for prioritisation of funding, taking investment cycles into account was proposed. Finally, that future infrastructure investments should be subject to risk analysis for climate change impacts was also viewed as important. 4

8 Response: The development of a cohesive funding model is a future measure to be considered as part of the National Adaptation Plan. Such a model could initiate the process of differentiating funding for specific adaptive measures from continuing investment in infrastructure maintenance. As climate change initiatives progress, their associated costs and benefits will be clearly demarcated. As a result of improved data collection of climate incidents, DTTAS will be able to systematically build upon evidence collection to inform climate change adaptation expenditure. In order to source additional sources of funding, as part of our participation in the Climate Change Adaptation Steering Group, we will investigate potential for EU funding sources to advance adaptation projects. The EU Multi-Annual Financial Framework provides for the integration and mainstreaming of climate action across key funding programmes which could also provide opportunities to access funding for certain climate adaptation actions. Other Submission Themes 1. Air/Water Quality & Biodiversity Preservation In general, it was suggested that air and water quality concerns, along with the issue of biodiversity preservation, should be explicitly supported within the remit of the Plan. One contribution highlighted that any adaptation and mitigation measures undertaken should ensure that no net loss of biodiversity is incurred as a result. In the context of public health, it was suggested in one submission that the connection between air quality and the effects of vehicle emissions should be further considered. Particular attention was drawn to the potential impact on water quality that may be caused by flooding and transport-related contamination. One respondent was of the view that consultation with Irish Water should be undertaken in relation to introducing climate adaptation measures to areas at risk of flooding, noting potential scope for future coordination in the development of Sustainable Urban Drainage Systems (SUDS) or in storm attenuation works. It was further suggested by this correspondent that consideration of heavy ground infrastructure in the adaptation plan could benefit from improved water, drain and sewage management, currently the responsibility of Irish Water. Response: DTTAS will seek to be cognisant of the issue of biodiversity preservation in the development of climate adaptation measures. Should any detailed adaptation 5

9 approach or measure be set out in later plans under the Climate Change Adaptation Framework, this may be subject to SEA and Appropriate Assessment (AA), which is the process by which environmental considerations are integrated into the preparation of plans and programmes. The link between air quality and public health and is being addressed through the National Mitigation Plan and through the development of the national Clean Air Strategy. Collaboration and consultation with relevant bodies such as Irish Water and local authorities will take place through an adaptation steering group chaired by DCCAE. In addition, the Local Government sector, in particular, will have a key role in adaptation planning given its role as a front line responder to the impacts of severe weather and climate change related events. 2. Active Transport & Urban Transport Policy Development A number of submissions made reference to Ireland s carbon footprint with a view to mitigating national carbon emissions through the development of active transport and urban transport policies. In general, there was broad support for modal shift from private car towards alternative modes of transport, wherein greater levels of government investment for public transport, walking and cycling will be required in line with projected increase in population. One contribution suggested that a permanent fleet of electric or hybrid cars should be provided in urban areas to serve as community taxis. The respondent also supported the introduction of new technological developments, such as driverless cars, in response to rising carbon emissions. Another submission noted that future investment for transport infrastructure must be balanced between maintenance of existing infrastructure and further development. One location specific suggestion was the development of an underground metro for the Dublin area. Response: These submissions refer to possible mitigation measures that could be implemented in order to reduce the greenhouse gases that are driving climate change. In line with the Climate Action and Low Carbon Development Act 2015, a National Mitigation Plan has been developed and published. DTTAS has contributed a chapter to the NMP outlining the potential measures available to help decarbonise the transport sector. 6

10 The suite of transport measures being proposed, as part of this process, include increasing capacity and provision of public transport and supporting modal shift, including active travel (cycling and walking). The sectoral Mitigation and Adaptation Plans have several synergies and cobenefits that will be developed and reported under the Climate Action and Low Carbon Development Act. It is recognised that these are likely to become more pronounced in successive plans as progress in mitigation and adaptation planning becomes more developed in Ireland. 3. Emergency Planning Particular reference was made to emergency planning provisions within the Plan in two submissions, calling for DTTAS and associated relevant actors to liaise with emergency planners in developing crisis strategies. A number of recommendations were made for specific emergency planning measures in relation to construction standards of transport infrastructure, assessing the readiness of transport infrastructure, and managing the effects of extreme weather. Response: Under the Emergency Planning Framework, DTTAS is the lead department for a range of transport-related emergencies and supports other lead departments for emergencies which affect travel and transport (for example severe weather). The role of DTTAS, in these situations, is to oversee and coordinate a national-level emergency response and DTTAS is active in fostering and maintaining strong working relationships with relevant government departments and public authorities in this regard. 4. Public Health One contribution called for further consideration of the issue of public health in the Plan in line with a recent climate change adaptation plan from the UK, which had noted that transport-related risks to health and social care delivery [require] urgent action in climate change adaptation plans. The contributor felt that public health and safety of road users, public transport passengers and staff should be prioritised, particularly in relation to issues such as heat stress. Another submission called for the development of a health surveillance system to collate data in relation to transport-related mortality. 7

11 Response: DTTAS affirms that public health and safety is a paramount concern throughout our policymaking. DTTAS will seek to be cognisant of the issue of public health in further developing the Climate Change Adaptation Plan, with particular sensitivity towards vulnerable individuals such as women, children, persons with disabilities and other persons and their health and safety needs, in line with the UN 2030 Agenda for Sustainable Development and the National Strategy on Women and Girls

12 Annex A: List of Organisations Submission No. Name Organisation 1. Dr. Tara Higgins Environmental Protection Agency 2. Various HSE Public Health Medicine, Environment and Health Group 4. Professor John Fitzgerald Climate Change Advisory Council 5. Michael Murphy Department of Communications, Climate Action and Environment 9

13 Annex B: List of Individuals Submission No. Name Address 3. Mr. Peter Lynch Dublin 6. Mr. Anthony Nagle Unknown 7. Mr. Eric Conroy Dublin 8. Ms. Maeve Thornberry Dublin 9. Mr. Tom Wall Unknown 10. Mr. Jim O Brien Dublin 10

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