CWI was pleased to work with the Centre for Environment Justice to develop a joint submission to the consultation on the development of a Clean Air Strategy.
Summary of Recommendations
We believe that it is imperative that air quality in Ireland be tackled in a systematic manner, ensuring that the National Clean Air Strategy (henceforth, “the Strategy”) protects the right to breathe clean air, while also delivering on Ireland’s obligations under the Aarhus Convention and the Sustainable Development Goals.
We therefore recommend the following:
- Right to Breathe Clean Air: the right to breathe clean air should be the central guiding principle for the National Clean Air Strategy.
- “Clean” air as the stated aim: in accordance with the World Health Organisation guidelines, the stated aim of the Strategy should be revised to ensure that it aims to deliver “clean” air rather than “cleaner” air.
- A Whole of Government Approach: The Strategy should be placed on statutory footing to ensure a whole-of-government approach and enhanced policy coherence.
- World Health Organisation (WHO) Air Quality Standards 2021: the Strategy should set out a path for Ireland to adopt WHO standards for air quality by the end of 2022 at the latest.
- Improved Specificity: The Strategy should be revised to specify how the priority areas, and the overall objective of the Strategy, are to be implemented and delivered in a timely manner.
- Monitoring and Accountability: The Strategy should be revised to include clear monitoring and accountability mechanisms that are measurable, actionable, and time-bound, with a view to ensuring policy coherence and protecting citizens’ rights under the Aarhus Convention.
- Address Inequality: the Strategy should identify measures to engage and consult with impacted communities on air quality issues in accordance with their participatory rights under the Aarhus Convention.
- Develop a new Energy Poverty Strategy: The last strategy to combat energy poverty lapsed in 2019, three years ago. An inter-departmental strategy must be introduced as a matter of priority and data collection on energy poverty must be improved so that progress can effectively be monitored in tackling this issue.
- Dissemination of Data: The Strategy should require relevant public bodies and local authorities to engage in greater public dissemination of real-time localised air quality issues as part of a national awareness campaign.
- Adopt a New Clean Air Act: we recommend the replacement of the Air Pollution Act 1987 with a new Clean Air Act which would consolidate existing legislation relating to air pollution. This new Act would provide greater powers to local authorities to deal with air pollution issues, as well as enhanced access to justice provisions for affected individuals and organisations.
