Public Consultation on the National Air Pollution Control Programme

The Department of Communications, Climate Action and Environment (DCCAE) is developing a National Air Pollution Control Programme (NAPCP), as required under Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants (the NEC Directive transposed by the European Union (National Emission Ceilings) Regulations 2018 (S.I. No. 232/2018)).

The NAPCP is intended to outline the pathway Ireland will follow to achieve compliance with the NEC 2020 and 2030 targets, projections of relevant pollutants and policy options.

Under the National Emissions Ceilings Directive and the transposing domestic legislation, the National Emission Ceilings Regulations, Ireland is required to prepare and publish an Irish Air Pollution Control Programme by 1 April 2019. The legislation requires that the NAPCP is subject to a public consultation prior to publication.

The Department invited submissions in relation to the proposed Air Pollution Control Programme and some of the main discussion points are detailed below. The consultation process closed at 5.30pm on Friday 5 July 2019.

Responses to the consultation were​ sent by email to: airquality@dccae.gov.ie

Alternatively hard copy responses can be sent to:

Draft National Air Pollution Control Programme Consultation,

Air Quality Division,

Department of Communications, Climate Action & Environment,

Newtown Road,

Wexford,

Y35 AP90

Responses to this consultation are subject to the provisions of the Freedom of Information Act 2014 and Access to Information on the Environment Regulations 2007-2014. Confidential or commercially sensitive information should be clearly identified in your submission, however parties should also note that any or all responses to the consultation are subject in their entirety to the provisions of the FOI Acts and are likely to be published on the website of the Department of Communications, Climate Action and Environment.

By responding to the consultation, respondents consent to their name being published online with the submission. The Department will redact personal addresses and personal email addresses prior to publication. We would draw attention to the Department's privacy statement:

The Department of Communications, Climate Action and the Environment requires responders to provide certain personal data in order to provide services and carry out the functions of the Department. Your personal data may be exchanged with other Government Departments and Agencies in certain circumstances, where lawful. Full details can be found in our Data Privacy Notice.

Recent research shows that air pollution has greater impacts on human health at lower levels than was previously understood. The impacts of air pollution (in particular nitrogen pollution) on biodiversity and habitats is an area of growing concern. This increased understanding of the importance of air pollution has led to a requirement for strengthening policy responses on air quality for which the Department of Communications, Climate Action and the Environment has primary responsibility.

At the same time, the impact of other sectoral policies on the quality of the air we breathe, such as energy, transport and agriculture, is becoming clearer. Initiatives to tackle greenhouse gas emissions over the last decade have led to the incentivisation of biomass for heating and diesel for motoring while in the agricultural sector increased livestock numbers has highlighted the impacts of, and challenges in, reducing ammonia emissions as well as greenhouse gases such as methane. These unintended consequences illustrate the need for a means to integrate air quality concerns into broader policy making. They also demonstrate the need to align air quality, climate and energy policy to ensure positive outcomes for human health and the environment.

At European Union level, the principal policy response has been the Clean Air Policy Package, comprising chiefly of a revised National Emissions Ceilings Directive (Directive 2016/2284/EU), a new Medium Combustion Plants Directive (Directive (EU) 2015/2193) and a proposal for a Council Decision on acceptance of the Amendment to the 1999 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution to Abate Acidification, Eutrophication and Ground-level Ozone.

The National Emissions Ceilings Directive (NEC Directive) establishes emission ceilings for 2020 and 2030 for five specified pollutants: nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOCs), sulphur dioxide (SO2), ammonia (NH3) and fine particulate matter (PM2.5). It also mandates the development of a National Air Pollution Control Programme (NAPCP) for each Member State. The NAPCP is intended to show the pathway Ireland will follow to achieve compliance with the NEC 2020 and 2030 targets. The format of the NAPCP is set down by the European Commission in implementing decision (EU) 2018/1522, which was adopted on 11 October 2018.

The draft National Air Pollution Control Programme

The National Air Pollution Control Programme includes:

• an overview of sectors and national policy frameworks in Ireland that impact on emissions of the 5 NEC pollutants
• an overview of the current outlook for compliance with NEC targets for each pollutant
• projections of relevant pollutant emissions to 2030
• policy options, measures and actions across sectors but in particular in the residential, transport agricultural and energy sectors aimed at reducing emissions of the five specified air pollutants

Aim of this consultation

This consultation seeks views on the draft NAPCP and asks for any additional analysis or evidence that could be considered. The Department encourages participation as all the proposed policy measures are still under discussion and it is possible to influence the content of the plan through feedback and responses to the draft.

Results of the consultation will be included in the final NAPCP. In particular we will include a summary of the outcomes of the consultation with respect to the selection of measures and the consideration of the most suitable instruments and actions to implement the selected measures.