two major crises facing government

Submission to Government from the Environmental Pillar, Jan 19th 2009

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Two Major Crises Facing the Government Submission to the Irish Government from the Members of the Environmental Pillar, January 18th 2009.


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Contents

1. Introduction 1

2. Addressing the fiscal and economic crisis 5

General points 5

Compliance with International Law 9

The Polluter Pays Principle 9

Public Authorities and the Low Carbon Economy 10

Low Carbon Cities 11

Environmental Resources 12

Drinking Water 13

Energy 14

Transport 15

Fisheries 16

Developing Local Economies 16

Import Substitution 18

3. The Smart (Green) Economy

A response to “Building Ireland’s Smart Economy”

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Appendix I. Home Insulation Schemes 24

Appendix II. Land Value Tax 32

Appendix III. Tree Cover Resources 33

Appendix IV. Coastal Erosion and Erosion Control 34


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1. Introduction The Members of the Environmental Pillar recognise the very serious situation facing the Government regarding both public finances and the wider economy. We also recognise that there is a parallel and potentially far more serious situation awaiting us if we fail to face up to the challenge of climate change and the serious impacts that our activities are having on the environment both domestically and worldwide. The most urgent and threatening symptom of this underlying reality is the challenge of climate change which we have less that a decade to prevent running out of control. In this light we would urge the Government and the Social Partners to avoid addressing shorter term but very serious financial problems in a manner that puts even greater stress on the fundamental ecosystem services that allow us to thrive as a race on this small planet. The continuing success of human society and social systems depends fundamentally on the preservation of the overall productivity, health and long term sustainability of the ecosystems and environmental services that underpin and supply many of the most basic components of human welfare such as healthy soils, clean water, a stable climate and clean air. An environmentally sustainable economy We welcome the recognition in last summer's NESC report that the foundations of a successful society include economic, social and environmental sustainability1. The interdependence of these three dimensions of sustainability is central to the analysis that the Environmental Pillar intends to bring to this discussion. This understanding must underpin how Ireland responds to all our current challenges. It is clear to us that we have been living beyond our means not just fiscally but also environmentally. In the first nine months of 2008 the human population used more natural resources than the Earth can replace in a whole year. In the same nine month period it also generated more pollution than the Earth can absorb in a whole year. In Ireland we had used our fair share of the Earth’s annual biological capacity by 1st of May 20082. The NESC report itself concludes that in the light of the findings of the Intergovernmental Panel on Climate Change "the current path of global development poses unacceptable risks."3 On a global basis, the notion of economies based on continuous growth has to be challenged and recognised as the road leading ultimately to the breakdown of human civilization. Infinite growth is not possible on a finite planet. The Environmental Pillar will work with the other Social Partners to explore how, in the context of a rapidly changing global environment, Ireland positions itself to prosper in a 21st century that will see a shift to a steady state economy. Working Towards a Sustainable Ireland In the light of the above and of the urgency of the situation we make the

1 NESC report 117, The Irish Economy in the Early 21st Century, June 2008, Paragraph 2.2.8 2 Living Planet Report 2008: http://assets.panda.org/downloads/living_planet_report_2008.pdf 3 NESC report 117, page 267.


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following proposals and where appropriate will follow with more detail later. We will also follow this paper later with further more detailed proposals for boosting the economy. One of the underlying themes in this document is that we need to become more self-sufficient, looking to establish ‘smart Irish based industries that are rooted in our society, are more resilient and less likely to leave when the going gets tough. Another is the strong connection between environment and tourism, We look forward to an active engagement with the Social Partners and with Government as we believe we can bring a new perspective which will contribute to lasting solutions being found. In this context, in Chapter 4 of this proposal, we make some initial responses to the Department of the Taoiseach’s Building Ireland’s Smart Economy – A Framework for Sustainable Economic Renewal. Dec 2008.


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2. Addressing the Fiscal and Economic Crises

In a crisis, social cohesion has to be preserved above all else - over efficiency and certainly, over political popularity. This requires that no one sector be singled out for particular pain and that the communication of the cuts is as important as the impact. It needs to be made clear that the burden will be spread as widely as possible, with the wealthiest making the largest contribution whilst the vulnerable and the barely coping are protected.

The tax base has a great deal of wriggle room for expansion and that this should be made use of rather than making major cuts and running the risk of losing the very important frontline public services that are already under stress through lack of resources. As a percentage of both GDP and GNP Irish spending on public services is relatively low by OECD standards.

We note in this context that already the Government is facing a range of financial penalties from Europe as a result of not implementing EU Directives4 particularly in the area of the environment. A major part of the reason for this is that the Government has failed to transpose the relevant Directives either on time or correctly. The failure to transpose includes the failure to provide the necessary capacity to the relevant public authorities to enable them to implement the parts of the Directives that central Government has made them responsible for. In the past 20 years the Local Authorities have been given an ever increasing implementation workload in relation to the environment, with the minimum of support from central government. At the same time Local Authorities have had their ability to raise finances severely restricted, particularly in the rural counties where both vehicle registration and commercial rates are at low levels.

General Points

1. Cost cutting measures can be achieved in the short and longer term by ensuring the sustainable use of indigenous resources; this should be the basis of a Smart Economy.

2. The tax base should be widened and should include a form of a Land Value

Tax. See Appendix II. This is fundamental to a sustainable society and economy as it will enable many other government programmes to be developed. New Taxes should be based on reducing the costs to the economy by decreasing the reliance on fossil fuels, as well as promoting an economy based on good planning. Any new taxation should not be based on cyclical sectors of the economy that leave the exchequer vulnerable. Taxes should be applied or increased in the areas of a) income taxes, b)

4 In the most recent example, on 15th January 2009 the Advocate General of the ECJ asserted Ireland had not transposed the EIA Directive of 1985 properly, and had failed to provide the European Commission with information relating to this case.


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capital gains taxes, c) GHG taxes (i.e Carbon Dioxide and Methane), d) property taxes, e) water taxes, f) aviation taxes.

3. Public sector and semi state pay should not be frozen or cut without other

protected or relatively privileged sectors taking commensurate cuts particularly in the financial sector and in certain parts of the legal and medical sectors, even if in relative terms the savings are modest.

4. Non basic remuneration should be considered for cuts first, such as the

high level of expense remuneration related to travel and maintenance. (See the “Carbon Economy” below).

5. If you want to save money ask the staff at the coal face how to do it. 6. The Number of Junior Ministers should be reduced to 15.

7. No serving TD should be receiving a pension from the state whilst still a

TD. 8. Public representatives that are entitled to a pension should only receive one

pension.

9. The number of Local Authority Councillors should be reduced whilst ensuring equal representation for every voter in the country.

10. Cut bonuses to Civil/Public Servants. The idea that 'if you pay peanuts you

get monkeys' has been disproved recently in the financial sector 'we've paid fortunes and still got monkeys'. The ratio between the entry level salary and the top level salary should not be more than 10 (or even lower) - i.e. entry level €25,000 means the CEO can't get more than €250,000

11. In recognition of the fiscal emergency, the government should aggressively

renegotiate contracts for goods and services from the private sector where these have diverged from the European norm.

12. Fixed price contracts for infrastructure projects should be enforced - bring

and end to ‘costs plus’ arrangements5

13. Full implementation of the EIA Directive would see greater public participation in Decision-making re development projects at the earliest moment in the development of a project. See Appendix III. In general this leads to better design and greater public ownership of the decision together with faster delivery and reduced costs. Had these procedures

5 http://valueireland.blogspot.com/2008/02/government-waste-taxpayer-to-foot-83m.html for

details of how a €9.3m contract became a €86m bill to the taxpayer for a sewage scheme in

Limerick.


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been followed then it is highly likely that the natural gas at present under the Atlantic off the Mayo coast would now be heating homes in Dublin.

14. Scrap the Homechoice loan scheme for first-time house purchasers - this

purely creates a developer subsidy by artificially creating a floor to housing prices and potentially is a Govt invitation to immediate negative equity for purchasers.

15. One off houses to pay full rate for connection to main services

16. Reduce the remit of FÁS to dealing with back to work and

unemployed/community schemes only, divert business funding handled by FÁS to Skillnets instead with more accountability and targeted spending on training initiatives.

17. Move from Road Tax and VRT to mileage charges. Tax the use of a car not

the fact of ownership. 18. Tax second homes, unoccupied homes and unproductive building land. 19. Annul all tax breaks on property/land/holiday home etc. In particular end

the situation where a landlord receives tax relief on rent that has already been subsidized by the tax payer (Social Welfare), e.g. in Section 23 housing.

20. Ensure that all outstanding planning contributions are paid. Planning

Departments are very quiet and now is the time for enforcement to be prioritised.

21. Pursue developers for their loans and if necessary take into state ownership

all the land-banks that the loans were secured against, allowing us to properly plan in future.

22. Scrap the storage of the electronic voting machines and sell or recycle the

machines

23. Don’t always use the ‘big consultancy firms’, we need to develop a wider indigenous expertise. Small is often more economic and efficient in this context.

24. Count the days that tax exiles are allowed in the country as any part of a

day - removing the ability to fly out of the country before midnight and it not counting.

25. On no account should public assets be sold in current conditions 26. Public Private Partnerships should not be used to short circuit the planning


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processes.

27. How EU funds are spent. There are various EU funds with agencies responsible for spend by set deadlines, linked to Leader and rural development especially. The spending is not integrated and most local boards do not include environmental NGO reps or biodiversity or hydrological expertise. Finance allocated to training in particular appears to go in all directions with no coherent plan as to where trainees might use the skills. At the same time there are official agencies which are falling down on their obligations to monitor and control due to lack of staff. If the same finance was used with both the national link and environmental value considered, there would be immediate gains both during the training courses and when completed. Despite the huge sums involved in the Rural Development Programme (€7 billion over 6 years) there is no publicly available environmental audit or assessment of the value of the measures taken to combat biodiversity loss, flooding, climate change etc.

28. Create a one-stop shop fully confidential whistle blower to allow employees

of public bodies and members of the public report dubious and inappropriate use of funds.

29. Regarding travel and subsistence for both public servants and public

representatives the following should be banned: • private car travel and expenses (public transport and/or taxis

obligatory unless not possible) • Claimable travel on government business inside Ireland by plane • Government or public representative Make-up, Hairdressing, clothing

expenses etc • Vehicles provided for work being used privately

30. Regarding travel and subsistence for both public servants and public representatives the following should be a requirement:

• Agency-booked international air travel and accommodation for

government representatives and civil servants (i.e internet booking at cheapest available rate only)

• Economy class allowed only

30. Review how much the HSE pays for its drugs. (the companies charge what they can get so the same drug could be a third of the price in Spain) Use generic drugs as much as possible.

31. Move to a prevention rather than cure model of health care 32. Reduce absenteeism. Changes in work practices are capable of saving

€500 million p.a. in HSE alone.6

6 http://www.irishtimes.com/newspaper/ireland/2008/1127/1227739033784.html


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Compliance with International Law and Conventions

1. Comply with International Law, Conventions and Agreements so that we don’t face environmental fines such as Kyoto and to the EU for non compliance

2. Ratify and implement the Aarhus Convention immediately to promote

greater public involvement in the decisions that affect their health and their environment. This would increase public awareness and monitoring of all likely environmental impacts, leading to a cleaner environment for the public future foreign investment and eco-tourism.

Polluter Pays Principle

1. Initiate more stringent polluter pays policies across the whole economy. It will broaden the tax base, help put the public finances on sound footing for the longer term, and begin the process of shifting taxation from goods (such as paid work) to bads (such as resource use and pollution). Just how much has the ‘pig crisis’ cost the country in cash and reputation?

2. Immediately transpose in full the EU Environmental Liability and

Environmental Crime Directives, requiring industry to take out insurance to protect both themselves and the taxpayer from the consequences of future Irish Steel sites.

3. Move to full and rigorous enforcement of IPPC Licence conditions including

those requiring public access to onsite environmental information. Whilst this may be seen as a burden on industry, both this proposal and that at 2 above will lead to a more robust, efficient and competitive industrial sector.

4. Put a tax on all products that cannot be fully and easily recycled. 5. Put a tax on pollutants emitted from industrial facilities and on emissions

from mobile telephone masts. This may reduce long term health costs. 6. Put a tax on PVC, polystyrene and plastic in food packaging as these all

have serious health implications as endocrine disruptors. 7. Put a tax on toxic chemicals, including pesticides and herbicides.

8. Put a tax on all one-way drinks containers. The recycling industry is

slowing down due to lack of demand, and even if it wasn’t we should be moving to long-life reusable containers ASAP.

9. A tax on excessive packaging of products. This will be a difficult measure

to put in place but one that merits attention at the EU level.


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Public Authorities and the Low Carbon Economy

1. Encouraging travel is undesirable for environmental reasons. The perverse incentive which rewards people working in the public service for driving vehicles with high CO2 emissions must be reversed. As well as reducing the associated environmental degradation, this will help Ireland to meet our commitments under the Kyoto Protocol and thereby make the prospect of a fine less likely.

a. All meetings organised by public authorities and their agents should be held in locations easily accessible by public transport.

b. The top mileage rates should be set at the rate currently given to the vehicles with the smallest engines and this should be given only for travel in vehicles with Band A CO2 emissions, with a declining rate as CO2 rates increase.

c. Walking and cycling should be encouraged. This will have a long term effect on the health of the employees, and reduce pressure on the health service caused by a range of illnesses related to the lack of exercise.

2. Roll out low energy/long-life bulbs to all public buildings and spaces. 3. Reduce and where possible turn off all outside lights on public buildings

except for safety reasons or for special occasions. 4. Electricity Use Management in Government and Public Authority Buildings7

Ireland was one of the first countries to introduce a national energy management standard (IS393) – To date not one government or state body has certified or even made moves to implement this standard. The typical energy savings are in the order of 6% in the first year of implementation and it is an ongoing programme of improvement.

5. Introduce proper sustainability indicators for all new buildings paid for by

the government. Design simple buildings that are easy to heat and cheap to build, using materials easily purchased in Ireland.

7 This is heavily promoted to large energy users in industry by Sustainable Energy Ireland

(currently over 70 companies have signed up for their Energy Agreements programme). It

involves companies implementing and maintaining an energy management system compliant with

IS393 as a published standard (it is very similar to ISO 14001 for environmental management - but

with the focus on energy). It is likely that this standard will become a European standard this,

possibly next year, with a full international ISO standard to follow.

If every Public Authority implemented this standard, this would have the effect of not only

reducing the state energy bill, but would also ensuring that the state sector contributes towards

Kyoto targets which are at the current rate of consumption unlikely to be met by Ireland and will

incur massive fines in 2020.


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6. Public Procurement rules must have a basis in the principles of

sustainability. 7. Promote a procurement policy of purchasing 50% of goods from recycled

and re-manufactured sources (Irish companies). This will create a market for recycled products and promote an Irish recycling industry.

8. Where different agencies or members of the same agency are involved in a

process where for example environmental sampling has to be done this should be streamlined to avoid perhaps 6 bodies going out each sampling for their own purposes. Set deadline of halving sampling (sample-taking expenses) by May 09, without loss of sampling sites or frequency. Involve suitably qualified NGOs in the review.

Low Carbon Cities

1. Make all city centres car free. This will stimulate the public transport sector creating jobs and discourage car travel. This has positive effects on the well-being of the public, reduces greenhouse emissions and ultimately reduces very expensive imports in the form of cars, and oil.

2. Develop good public transport links between the cities, going north-south

as well as Dublin-centric. Start with the completion of the Western Rail Corridor as a priority.

3. At the same time remove subsidies for air travel. 4. There certainly would be a saving on the fines that we will have to pay on

our greenhouse emissions if climate neutrality is made a high priority in cities.

5. The use of outdoor heaters to facilitate smoking and eating outside should

be banned. 6. Reverse the announced cuts to public transport. With the downturn taking

the pressure off the capacity of the capital’s public transport system, now is the time to encourage modal shift not to cut services. Introduce a congestion charge and tolling of private vehicles in areas which are adequately served by public transport and use the proceeds to increase the subsidy to public transport.

7. Implement and give teeth to the parking taxation announced in the last

budget. €200 is trivial when parking is €2 an hour in Dublin


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Environmental Resources

1. Woodlands have a great potential for providing revenue, developing rural economies and local infrastructures, acting as carbon sinks etc. Trees now cover 16% of the land area of the Republic, according to the National Forest Inventory (2007).The two main components are Plantation Forest/Woodlands at 10% and Hedgerows/Field Boundaries 3.9%. Some initial ideas for developing this enormous resource are given in Appendix III

2. Protection and creation of wetlands for carbon sequestering and

biodiversity. 3. Encouraging long-term afforestation of native woodlands to help meet

Kyoto targets and develop eco-tourism

4. Lower VAT on recycled and remanufactured goods at point of sale. 5. Improve decision-making through training in the sustainable use of natural

resources. Sharing and developing the expertise of NGOs and private sector and supporting the development of sharing existing experience, as well as building on and encouraging the scientific (ecological) education.

6. Incorporate the role of our natural environment in dealing with a changing

climate into adaptation strategies for inland flooding and coastal sea level rises. This will reduce costs and reduce damage to communities as well as having environmental benefits.

7. Export-led economic growth includes tourism which depends significantly

on the natural environment and our landscape as does quality of life and social cohesion. Marine and terrestrial wildlife contribute significantly to thia. Restoring competitiveness in this area by adhering to the requirements of European Directives, such as the Habitats and Birds Directives, we will achieve longer term cost savings.

8. Coastal Erosion Control: Halt all new erosion control funding (~ €15

million/annum) until we have a national erosion control policy. Work on creating such policy with public participation, which is funded from existing LEADER EU funds. Maintain and restore existing erosion control, especially dunes and old seawalls by involving local communities and using existing training grants from EU funds like LEADER to put the expertise and structure in place. See Appendix IV for more detail.


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Drinking Water

1. Stopping water fluoridation would produce8: i) savings of €3million per year in import cost of fluoride chemical (Dáil Answer of 12/6/06 stated cost of chemical in 2005 was €3.2million) ii) and another conservatively estimated €33 million per year savings in other operating and capital costs (Based on UK cost of new plant of £270,000). These savings contingent on ending fluoridation in 360 drinking water treatment plants.

2. Water charges

Introduce water metering. Every household to have a water allowance per capita with charges for amounts above the allowance. Special circumstances to be dealt with sensitively. It costs the taxpayer €650/ year to supply each one of us with potable water9. Those that waste water should pay the price and those that don’t should pay less.

3. Develop an ecosystem approach to protecting water supplies, not just end

of pipe solutions, by protecting the sources of the water. This is cheaper in the long-term. The result of not doing so can be seen all to clearly by looking at the one example of Galway where: an enormous harm was done to tourism; a huge amount of time and energy was wasted; and Ireland lost investment by a large multinational when Johnson and Johnson decided not to invest in Galway because the water quality was so bad.

4. Comply with all the water related European Directives. 5. Alternative systems of dealing with human faeces and urine should be

investigated with urgency. The costs of the present water based sewage processing in terms of wasted potable water and energy, as well as the end of pipe pollution are rapidly increasing.10

8 Fluorosilicic acid is added to nine billion litres of drinking water in Ireland every day under a fluoridation policy dating back to 1960. This practice has been long abandoned in the rest of Europe as its benefits are not justified anymore. Moreover, this substance (Fluorosilicic acid), classified by the EU Waste Directive (91/689/EC) as hazardous waste, is not an authorised medicine. While the waste imports costs €3 millions annually, water fluoridation involves other major costs in plant and equipment. In over 360 water supplies countrywide the dosing and monitoring equipment has to be regularly upgraded, and precautions are necessary for long-term storage of this toxic chemical. The provisional figure we estimate, based on UK data, for the operating cost is €9million. The water treatment plants using fluoridation have to be regularly upgraded, and although figures on the costs have been difficult to access upgrading is estimated to cost approximately twice as much as the materials and operating costs combined per annum. Irish drinking water is used for disposing of foreign hazardous waste as 99.5% of fluoridated water is wasted since only 0.5% is drunk by consumers. The costs to society due to impacts on health are unmeasured. 9 Sue Scott. ESRI. Presentation Liberty Hall 10th January 2009. 10 The Government will create more jobs if it permits urine separation toilets in domestic houses to separate and recover urine as a liquid fertilizer to be reused in agriculture. The availability of low cost liquid fertilizer will be more economic to farmers who have recently seen increasing costs for


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Energy

1. Home Insulation. For the average house, a saving of 30% of the heating bill is easily achievable. This is very significant, not just in relation to reducing greenhouse gas emissions, but should also be seen in the light of the island wide increases in fuel poverty that were highlighted by the Institute of Public Health (IPH). The IPH pointed to the fact that there were 1950 excess winter deaths in 2005, a figure that was likely to increase with the economic downturn and the rapid upward trend in fuel prices. Fuel poverty should be tackled for the long term by reducing the need to heat the homes of the vulnerable and this will produce a commensurate reduction in the importation of expensive fuels and carbon emissions. More details of this are given in Appendix I.

2. Current Irish energy strategy may be summarised as much talk about wind

and renewables, while at the same time uncritically allowing a new generation of inefficient CCGT gas plants locking Ireland into long term supply and price unpredictability of imported gas, as well as massive CO2 emission increases. There is a place for gas in the coming decades in the energy mix but this should be limited to small scale ‘peaking’ plants of limited number and, more particularly, small scale combined heat and power (CHP) plants which, for example, would recover heat wastage in use for district housing schemes.

3. An immediate moratorium is necessary on further CCGT plants, for base-

load on the grounds of emissions and downstream cost exposure and supply risk. With practical application of wind and tide power being some time away, Ireland is in the unique position to set a global lead in wind generation which is capable of supplying more than 50% of the national grid if appropriate distribution and grid connection can be achieved. However, achieving this needs the sort of radical initiative which built the Shannon hydro-electric scheme in the 1920s.

4. The current strategy for on shore wind development is ineffectual and non-

strategic, leading to a plethora of small scale applications across the country, achieving very little in the scale of generating capacity needed. More seriously, many of these sites are being badly chosen in areas with deep blanket bog cover. The only effective means to change the large-scale capacity required is to identify optimum locations for large-scale wind energy clusters of up to 1000MW in areas of good wind speed combined with low population density and low ecological or landscape sensitivity.

5. Wood-fuel for energy. Ireland is one of the least forested countries in the

temperate world. Only about 10% of the land area is covered by woodland. Simply planting more trees would have value: they will soak up CO2, reduce the risk of catastrophic flooding in times of intense storms, and possibly

conventional chemical fertilizers.


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help reduce summer peak temperatures. Thousands of local people could be employed planting and looking after the trees. But the even more important objective is to reduce fossil fuel use by replacing coal and gas.11

6. All thermal processes developed for the production of electricity regardless

of scale should incorporate Combined Heat and Power (CHP), giving efficiencies of energy conversion of 80% compared with c. 35% in traditional power plants. This extra dimension of heat production can be used for town space heating and/or process heat for industrial purposes. All electricity generation bodies should be required to show how they intend to develop and use this extra resource when they apply for planning permission.

7. Outside lights on all buildings should only be used for reasons of security,

and where appropriate for special occasions. In general this is a vanity and both a waste of resources and a source of light pollution.

8. Serious and rapid implementation of effective smart metering and

interchange for small scale home generators - whatever power source - wind, solar, hydro, geothermal etc - shouldn’t need financial incentives for home users.

9. Develop really ambitions targets for sustainable energy 10. Move from Road Tax and VRT to mileage charges. Tax the use of a car not

the fact of ownership. Transport

1. Scrap aviation fuel subsidies. 2. Provide no further funding for the development of airports. 3. Invest heavily in a low carbon public transport infrastructure on the basis of

value for money rather than prestige/hi tech. Smart doesn’t have to be complicated.

4. Cancel all Government funding for new road projects and airports. At €10

million/Km 200Km would give the necessary saving for this year of €2

11 In other northern countries, wood-fuel provides a substantial fraction of total heat needs

through district heating systems that burn the wood in central plants and then distribute hot water

to local homes. This replaces the need to use gas or oil. Increasingly, these wood-fuelled heating

plants are also generating electricity as well using turbines. Ireland could aim to install thousands

of small-scale wood-burning (or, more likely, wood gasification) plants dotted around forested

areas feeding energy into the National Grid.


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billion on the capital budget. Which could be directed to house insulation and public transport

Fisheries

1. We have an enormous and under-researched fisheries resource in the oceans surrounding Ireland. It would be very easy to destroy it.

2. Development of National Marine Conservation Centre12 - creating

jobs/research & development - particularly for fishermen who are in a unique position to collect data.

3. Invest in developing Marine Tourism using the knowledge and skills base of

the existing fishing industry 4. Assess the fuel consumption and the carbon footprint of fishing fleet, and

remove subsidies from fuel guzzling trawlers13 5. Take a good look at fishing subsidies and divert funding into creating a

more productive and sustainable mollusc farming industry (oysters, scallops, mussels) - ensure harvesting is by diver and not dredging (protects seabed and creates employment)

6. Control recreational angling as part of CFP14(Common Fisheries Policy). 7. Encouragement of indigenous line fishing and labelling at point of sale. This

would be valuable marketing tool. Developing Local Economies

A sense of wellbeing is important not just for individuals but also for communities. Whilst this is generally the case, it is particularly so in times of difficulty. So it is important to empower communities and let people solve employment on a local basis as they see fit. The worst thing about a recession is loss of hope and confidence leading to a longer recession. The focus must be on re-skilling and local empowerment.

Instead of offering to give a big company €30 million to stay in an area offer similarly big financial incentives to local groups to get training and set up in small innovative businesses that they want to do themselves. The necessity to roll out high speed broadband is an obvious factor here. None

12 It’s important to note that the National Marine Conservation Centre would be a social economy model, developing employment & training opportunities and strengthening the local social economy. 13 Some “twin-riggers” are using 1600 litres a day 14 The Irish Seal Sanctuary Fishery Advisory Group is trying for sustainable use of Marine resources for all. We are trying to get EU to protect spawning and nursery areas from non-selective commercial methods, not all fishing. We have to consider socio-economic costs.


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of the proposals below cost much and they can be rolled out through City Councils and New County Partnership Companies if given enough directives to this effect. Diversity and small scale are viable in a scaled down economy and keep up the sense of nation wellbeing when GNP is down.

The 9 main areas we should develop short and long term are:

1. Small scale cottage industries related to craft and organic food production as they have huge value added in people’s self worth and pride seen in craft and artisan food fairs.

2. Tourism should relate to the first point and our tourism brand should be

built around green, local, and eco as this is what people have always come to Ireland for. It will also enhance quality of life for Irish people too.

3. Develop indoor farmers market spaces, as a way of lifting local

confidence and resilience and supporting agriculture and reduce food miles and carbon footprint

4. Support community gardens15, which are a cheap way to do community

development, training, and make available affordable healthy food to low income families reducing health spending as mental and physical health has been shown to improve through such involvement. …it is the terrestrial equivalent of “give a man a fish and he feeds for a day -teach a man to fish and he feeds for a lifetime”

5. Make unused land banks owned by banks and developers available for

food growing while development plans and building are suspended. 6. Support innovative approaches to housing such as social housing-eco

villages. This will help keep construction going at a slower pace and at the same time up-skill workers through eco-building techniques.

7. Support Transition Towns initiatives and bring in eco-municipalities and

Natural Step principals. This latter rejuvenated depressed towns in Sweden in the 1990’s

8. Use post vans as post buses for rural areas and put big bike racks on

BusEireann buses to encourage bike use. Irish Rail should be mandated to enable the carrying of Bikes on their trains.

9. Re-invent Ireland as an organic food and drink island. Create incentives

for the production and consumption of organic food here to promote a high quality product culture.

15Community gardens take many forms, but essentially as the name implies these are neighbours coming together to grow food crops.


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Import Substitution

1. Planting a greater volume of quality hardwood trees in Ireland will help offset our reliance on imported hardwoods. This particular practice carries a very heavy carbon, environmental and social footprint.

2. Two of the largest import costs are energy and motor cars. The downturn

in the economy has caused a minor volume drop in the former and a major volume drop in the latter; these are trends that should be encouraged by investing heavily in public transport.

3. Sustainability criteria should be one of the main considerations in decisions

re public procurement, and this includes the impact of the importation process


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3. The Smart (Green) Economy

In principle, we support the idea of moving to a smart economy as outlined in Building Ireland’s Smart Economy – A Framework for Sustainable Economic Renewal, 16 as a way forward through the current financial problems, but it must be a Smart Green Economy if it is to deal with the future threats of: energy security as peak oil approaches; loss of water and food security; and the impacts global warming. All our plans for the future must be predicated on the knowledge that infinite continuous growth and attendant over-use of the planet’s resources is incompatible with the finite reserves of our one planet. What follows is a response to some of the initiatives outlined in this document. Action Area 1. Meeting the Challenge - Securing the Enterprise Economy and Enhancing Competitiveness

• Other than completing currently contracted road schemes and maintenance and repair of the existing network there should be no further capital outlay on roads

• Investment of capital should be focussed on:

• Green technologies - support innovation, research & development and role out of ‘green’ technologies especially next generation renewable energy. • Necessary interconnectors • Improvements of insulation etc of c. 1 million houses (see Appendix A) • Smarter meters. • Insist that all new housing programmes are to the highest standard • Training for installers and other technical and craft workers involved in fitting of systems to improve energy efficiency

Action Area 2. Building the Ideas Economy – Creating ‘The Innovation Island’ In general we support this concept and believe that the emphasis must go into the development of real green technologies and associated entrepreneurial skills and this area should be the target of the greater part of this action area. Ireland already has some companies that are at the leading edge in tidal and wave power. • Action Area 2.4 A particular focus will be opportunities arising for research in the renewable

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Building Ireland’s Smart Economy – A Framework for Suatainable Economic Renewal. Dept of the Taoiseach, 2008


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energy and environmental technologies areas (see Action Area 3), including the development and commercialisation of ocean energy. This is reflected in the fact that Science Foundation Ireland recently added a third pillar of energy to its remit. Unoccupied grey-field sites (where developments are completed lying idle) should be turned around into space for new businesses to start. Create a Waste Recovery Board to be responsible for all waste generated in Ireland. Their role is to ensure it is not land-filled or incinerated but re-used or recycled or re-manufactured. Create ECO parks for new companies to exploit the waste resources to be managed by the Waste Recovery Board (WRB) e.g. R&D into novel manufacturing ideas. These can be exported as a service also. Waste Recovery Board (WRB) to manage Ireland’s waste resources and ensure a secure supply of waste resources for the new ECO companies and build a guaranteed market for their sales. Lower VAT on recycled and remanufactured goods at point of sale. Mandate FAS to provide sales/marketing courses for the unemployed. Create a large national facility of Call centres, staffed by FAS graduates and paid basic wage (above dole). Make them available as a free resource to Business, Bord Failte, Bord Bia etc to sell and promote Ireland abroad. • Action Area 2.6 Expanding tourism should focus on a low carbon future. This must be targeted at persuading the population to holiday in this country. There should also be a drive to get all tourist facilities to adopt the national energy management standard (IS393) as part of the eco-tourism drive • Action Area 2.8 and 2.9 There is an urgent need here to incorporate training in skills associated with green technologies. Action Area 3. Enhancing the Environment and Securing Energy Supplies In general this section is supported by the Pillar. Action Area 3.1 • The Western European coastal shelf DC grid should be pursued with vigour to enable a stable interconnection and ready availability of access for marine energy sources. • Are the smart meters being looked at are smart enough? They need to know the time of day and the load and only allow devices to be turned on in particular conditions. Action Area 3.2


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• A much more extensive ‘Warmer Homes’ scheme should be initiated. See Appendix A. Action Area 3.6 • It is vital that the Government and all economists understand that we are building up insurmountable problems for the next generations because continuous (infinite) growth is impossible when we are using up and polluting the finite resource that is our planet. Sustainable development as conceived by the government is an oxymoron. Whilst we welcome the attempt to measure the environmental impact of economic development, it is already blatantly clear that the impacts are enormous. For too long when ministers use the term sustainable development they mean “economic growth that keeps on going” rather than “operating within environmental limits”. There are examples even since the publication of the Smart Economy document that both the Tanaiste and the Minister of Finance understand the word sustainable in the title to mean sustained rather than environmentally sustainable. Action Area 4 Investing in Critical Infrastructure The NDP, Spatial Strategy and Transport 21 need to be re-evaluated in terms of real environmental sustainability. Other than completing current contracted inter-urban motorways no further major road programmes should be initiated. The emphasis must be put on Public Transport, including Rural Transport. The Government should use part of this capital to invest seriously in a ubiquitous and cheap broadband access for all. The absence of a published National Development Strategy is a serious issue, leaving planners and policy makers without a yardstick to measure against. Action Area 4.1 • As already stated under Action Area 1, other than completing current contracted inter-urban routes, no further major road programmes should be entertained. The emphasis must be put on Public Transport, including Rural Transport. • Dublin Airport – Future development of airports should not be supported by government funds • The Western European coastal shelf DC grid should be pursued with vigour to enable a stable interconnection and ready availability of access for marine energy sources. • Ensure that all investments in housing, schools etc are built to the highest environmental/energy standards Action Area 4.2 • Invest in next generation broadband to the whole country – it’s more important for our economy than building roads.


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Action Area 4.3 • The review of the National Spatial Strategy is timely and should take into account the need to move towards public transport and away from cars. Action Area 4.4 • Land zoning & rezoning has been part of the problem in the past with excessive building of inappropriate housing estates in many parts of the country17. Action Area 5 Efficient and Effective Public Services and Smart Regulation • We support efficiency, effectiveness and value for money. But we would also stress that our public servants should be encouraged and their morale boosted at every opportunity. This is a time when we need them to be at their best, and also a time when the media appear to think that they are there to be used as whipping boys and girls. We would also recommend that excellent the Regulatory Impact Analysis process is given a much higher public profile in order to promote smarter regulation and greater public involvement and buy in. • The implementation of many of the roles of local authorities would operate better and be more cost efficient if the smaller ones were operated on a regional basis. For example, the Environment Sections of Sligo Borough Council and the County Councils of Sligo, Leitrim and Roscommon should only have one management team. This would free up resources to employ more frontline staff implementing and enforcing the legislation that the Local Authorities are responsible for. At present because of the cutbacks, the number of frontline staff has been dramatically reduced, whilst there are for sake of example four senior management staff members in each of the above Local Authority’s Environment Sections performing the same management roles with ever decreasing frontline resources.

• It is also nonsensical for Leitrim Co Council or Sligo Borough Council, to be trying to effectively implement all the legislation that it is required to do, the very same legislation as Dublin City Council. Leitrim Co Council and Sligo Borough Council respectively service populations of c.20-25,000 and the latter maybe 20 times as many. It is not suggested that the Democratic oversight be reduced, but that the fulfilment of the roles of the Local Authorities be made more effective. • Following on logically the same should apply to those of the 48 Town Councils and 5 Borough Councils at present running their own services. These should be amalgamated with the relevant County Council. This is a

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Almost every rural village on the Shannon now has a half empty estate with no likelihood of the houses ever being occupied. In Cootehall Co Roscommon previously a village of 20 houses there are now over 50 new empty terraced houses


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matter of scale. At present Athlone Town Council for example has an annual Budget of c. €5 million. It is not suggested that the democratic oversight be reduced.


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Appendix I Home Insulation Schemes.

Encouraging households to undertake energy saving investment – Summary / introduction This is a package of proposals put forward by the environmental pillar of social partnership. Five measures are proposed which do not involve any additional government spending and lend themselves to immediate implementation if endorsed by the social partners. A sixth proposed measure, which would entail the commitment of major finance, is also described which in part builds on the first five. The six measures concern:

1. advertising the Building Energy Rating of homes, 2. aligning the levy on second homes to take account of energy

rating, 3. factoring the energy profile of homes into mortgage

applications, 4. making training courses available for energy-saving

craftsmanship, and 5. enabling credit unions to better serve demand for home

upgrade loans. 6. a major drive to insulate 1 million homes

All of these measures, directly or indirectly, will strengthen and/or serve demand to save energy in the home. In turn, making Irish homes more energy efficient will deliver a range of benefits including greater employment, lower energy bills, reduced fuel poverty, lower carbon emissions, and a better local environment. An important aim of government is to reduce and eliminate the fuel poverty experienced in 150,000 homes in Ireland, a level the World Health Organisation has described as shocking.18 Lowering carbon emissions also helps to meet our Kyoto protocol commitments, aiding Ireland to avoid substantial financial penalties which would otherwise result. Through its package of home insulation measures, the UK expects to reduce carbon emissions by 3 per cent annually,19 making a very significant contribution to its climate change pledge. The immediate priority: increase awareness As can be seen the benefits of the proposed package are widespread, and a

18 Gartland, Fuel poverty figures here shock WHO, Irish Times, 29 August 2008. 19 http://www.defra.gov.uk/environment/climatechange/uk/household/supplier/cert.htm.


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significant increase in the implementation of energy saving in Irish homes will cause unit costs to fall and further raise awareness, leading to even greater demand and take-up. Lack of awareness is a major barrier to the take up of energy saving steps in the home, something noted in a wide body of literature on the topic.20 Alerting homeowners to the potential benefits of a more efficient home – and making this dividend live and tangible – is vital. We need an Ireland where homeowners and householders ask themselves: what is an energy efficient home? What could it mean for me? And how do I find out more information on that? How can I make it happen? After information is secured, and an independent assessment of the home has taken place, the householder will face more detailed questions. These will typically concern implementation in the light of budgetary limits while further queries may focus on getting quality workmanship at a fair price. But, for a vast cohort of households, awareness remains the critical stumbling block. To increase awareness we propose building on a measure already being implemented, namely the requirement from 1 Jan 2009 that all homes for sale or rent must be accompanied by a Building Energy Rating certificate (BER).

1. Advertising Building Energy Rating The Building Energy Rating certificate, or BER, measures the energy efficiency of the home from A to G, with G being least efficient. Each BER is accompanied by an advisory report offering step-by-step guidance to improve the comfort and reduce the running costs of the home. In other words a BER doesn’t just let the householder know the current position; it also shows the way to better energy performance. The advisory report takes a step-by-step format, listing the most cost-effective measures first; for budgets of €500 and less a BER still presents a ‘to-do’ list. Energy rating has the potential to awaken greater interest in home energy efficiency, even among those not buying or renting a home from 2009. Feature newspaper articles on the introduction of BER have brought many of the steps that households can take to raise their energy efficiency to a wider audience.21 But much more needs to be done. What we suggest is that it be mandatory not simply to conduct the BER, but also to include it in advertising and promotional material for the home. Under the rules in force from 1 Jan 2009, a BER is mandatory for all homes but sellers or lessors do not need to display the BER upfront; rather, “a person who,

20 http://www.defra.gov.uk/environment/climatechange/uk/household/supplier/pdf/evidence-call.pdf. 21 Thompson, Will your home pass the test? Irish Times 20 December 2008


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after 1 January 2009, offers a building for sale or letting, or any agent acting on their behalf, is required to produce a copy of the BER certificate to any person expressing an interest in purchasing or taking a letting in the building. A person who contravenes these requirements commits an offence and is liable to be fined, on prosecution by the Building Control Authority in whose functional area the building is situated, a sum not exceeding €5,000”. However, in a number of requests to estate agents in early January, all of which concerned specific properties, the agent neglected to include the BER in material subsequently sent out. It’s not that there are insufficient assessors to do the work; there are plenty. As of late December 2008 there were 1,030 BER assessors registered with SEI for new homes, and over 660 for existing homes. A further 2,800 had undergone the requisite training by the end of the 2008 and the Departments of Energy and the Environment expect a proportion of these to register with SEI as demand for BER assessments increases over the course of 2009. It does not make sense to test compliance with the BER regulations on a property-by-property, agent-by-agent basis. In any event, the BER will have to be included the legal set of documents that passes between the parties when a sale or lease is concluded. And if a BER must exist for every property sold or leased (subject to limited exceptions including protected structures, for example), it makes sense to advertise it. What we are proposing is essentially a complimentary measure - that the BER of the home be displayed as part of any advertising or promotion of the property. We suggest that not less than 15 per cent of the content/display area be allocated to conveying the BER, and that the rating itself be clearly communicated. This complimentary measure would apply to newspaper advertising, internet promotion, on-site advertising boards and hoarding (subject to size parameters). We do not believe this would place any significant higher cost burden on transactions. In the case of small newspaper ads with no more than 30 words (typically used in the rental market) the requirement can be reduced so that only six character spaces are required; “BER C1”, for example. One immediate result of the above measure is to inform would-be purchasers and lessees of the efficiency of the home without the need for enquiries to the agent, landlord, or vendor. Heating expenses and upgrade costs will be much more readily factored into decision making. The communication of BER across the full range of media formats will raise its profile and stimulate more households to conduct energy assessments. Increased investment in energy saving measures will be a dividend. It may be possible to reduce current government expenditure by the introduction


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of this measure. Through Sustainable Energy Ireland, the State dedicated significant resources during 2008 to raising awareness of BER.22 The adoption of the proposed measure will familiarise more people, and at far lower cost, than any promotional campaign. We believe this change can be put in place by mid 2009.

2. Aligning the levy on second homes with Building Energy Rating A €200 annual levy on owners of second homes was introduced in Budget 2009. We propose that the charge be amended in the next Budget as follows:

• A-rated homes are charged a lower fee of €100 annually, • B-rated homes remain charged €200 annually, and • Homes rated C, or less, are charged €350 annually.

It may make most sense to recast the measure to spur owners of second homes to upgrade them: where owners do not show that their property achieves an A or B rating, the levy becomes €350. To avail of the €100 levy for A rated homes, or the €200 levy for B rated homes, owners should submit a copy of the BER cert to the relevant local authority (local authorities being responsible for collection of the levy) by registered post or deliver it by hand.

3. Obliging lenders to establish whether buyers of homes rated C or less plan to upgrade the home or pay higher costs on a continual basis

Once built according to the regulations introduced by Minister Gormley in 2007, newly constructed homes should achieve at least a B rating. However, older homes will continue to make up a high proportion of transactions, and consideration must be given to their financing. It is important for Government to ensure home running costs are not neglected in the housing finance equation, all the more so since the State took responsibility for bank liabilities in 2008. Buying a G-rated home for €280,000 is much more demanding than buying a €280,000 A-rated home, but few lenders appear to give weight to this. All other things being equal, the purchaser of a poorly-rated home will either have to invest in its upgrading or suffer higher energy bills together with draughty living conditions. If the buyer proposes to continue paying high energy bills then he or she is exposing themselves to fuel price risk over the medium to long term. If, on the other hand, the buyer plans to upgrade the home then that finance is most competitively secured with the mortgage itself.

22 See www.sei.ie for details of the national radio advertising campaign conducted in mid 2008 to highlight BER.


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The purchaser has a simple choice to make: upgrade the home or foot higher bills, and according to this proposal, that choice would be elicited by the lender when a home rated C or less is being financed. An argument might be advanced against this proposal along the lines that it represents extra paperwork for prospective purchasers and lenders. On the contrary, in the case of lower-rated homes, it affords a much fuller picture of the total exposure of the purchaser. Moreover, it assists the purchaser to face - and make - a key decision, and, by doing so, it provides for more soundly-based loan practices by lenders. Whether or not a prospective purchaser will upgrade an energy-inefficient home is a key decision, and it can be anticipated that good lenders will welcome a universally-applicable rule bringing consistency to this area. Assuming the social partners see merit in this measure, it is proposed that the next step is to liaise with the Irish Banking Federation and Financial Regulator and establish the best means of bringing the measure into force.

4. Training courses for energy-saving craftsmanship As noted above there are plenty of qualified BER assessors. Lacking, however, are trained craftpersons able to undertake a wide range of energy-related enhancements. If a small fee is charged to people taking the course, then providing training to undertake a series of high-quality interventions at reasonable cost can be self-financing. Also, providing these courses will save the State paying jobseekers’ benefit that would otherwise fall due. What work will such a training course cover? Who will run it? And who will teach it? First, we must establish what already exists. A review of the 48 day-courses available from one FAS office (Limerick city) shows that while one can become trained in archiving and lakeshore development, there is no day-course in the area of home insulation / energy saving.23 Similarly, a review of FAS courses in the north Dublin area confirms the presence of training for construction operatives, but nothing in the home insulation and energy saving sector.24 A new course must cover a range of basic measures recommended in BER advisory reports. The ability to block chimneys, lay insulation, draught-proof doors and windows, erect shutters and add basic heating controls (or fixing dials improperly set) must all be imparted. Clearly, this work touches upon a number of disciplines. There are, for example, a number of different means to seal up a chimney. If a household is happy not to have an open fire again, then the chimney pot can be taken off and the top covered with 10 – 15 cm of concrete.

23 http://jobbank.fas.ie/servlet/Watis?SESS=57378_6&SERVICE=CRITERIUMSELECT&VALUE=230 24 http://jobbank.fas.ie/servlet/Watis?SESS=57378_6&SERVICE=CRITERIUMSELECT&VALUE=170


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For a temporary seal a ‘chimney balloon’ is inflated in the chimney breast and a ‘Chinese hat’ is placed over the chimney pot to prevent dampness. All of the other areas mentioned above – insulation, draught-proofing, shuttering and heating controls – each have just as much complexity; hence the need for a detailed course which will equip a new generation of craftpersons to undertake this work. A way to take this forward may be for the social partners to write to FAS requesting that its assistance in putting in place courses on a nationwide basis.

5. Enabling credit unions to better serve demand for home upgrading

Purchasers of new homes in need of upgrading are likely to secure the best finance possible through a mortgage. But there are tens of thousands of homeowners who will want to finance the upgrade of a home they already own. Almost 3 million people are members of Irish credit unions and there are some 500 credit unions nationwide. The strong record the credit union movement enjoys among consumers stems largely from its not-for-profit status, and also because credit union loans can be repaid faster than provider for in the finance agreement without penalty to the borrower. A great many credit unions are no doubt already well-equipped to arrange home upgrade loans. The aim here is simply to see their capacity strengthened so that virtually all householders have access to not-for-profit finance to undertake energy saving enhancements. The Irish League of Credit Unions already offers business development support to member unions: the implementation of this proposal would simply see the ILCU offer a comprehensive programme of business development support for energy saving loans to all members. To give some idea of the sums involved, a leading architect has calculated that €25,000 is the cost of making the average Irish home energy efficient. The cost varies widely from between €2,000 and €5,000 for an apartment, to €20,000 for a terraced house, and up to €40,000 for stand-alone housing. 25 Some unique features of a loan for energy saving improvements are worth highlighting. When a typical small loan is taken out - to buy a car or extend a house, for example - the lender will usually look to the borrower’s employment situation to assess ability to repay. The lender will have to bear in mind that, by taking out the loan, the borrower may in fact be raising their cost of living (fuel for the car and greater home heating costs, in our examples above). So the lender

25 James Pike of OMP Architects at a roundabout of the Feasta Smart Tax Steering Group, 20 October 2008.


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is likely to focus on job security, employment track record, and likely future income. But when a loan is granted for energy saving measures, the investment actually saves the borrower money, something which cannot be said of any other loan. It is in calculating the likely savings accruing to the borrower that credit unions may benefit from some assistance. The monetary gain from upgrading a home for G to B, for example, will not be proportional to the headline rating because of “comfort taking”, which is where householders heat more rooms than they would have done before, or raise the thermostat a degree or two. In the UK it is estimated that, on average, comfort taking means that 50 per cent of the upgrade savings need to be discounted.26 In order to access information on energy saving finance for a business development support package, the Irish League of Credit Unions may benefit from working with Sustainable Energy Ireland. This proposal – if approved – is essentially a request by the social partners to the Irish League of Credit Unions (ILCU) to establish a business development support programme so that all member unions are well-positioned to offer energy saving loans. Having delivered such a business development support programme, it is envisaged that the ILCU and/or member unions will engage in some advertising in order to highlight their competence in the area of lending. 6. A major Drive to Insulate 1 Million Homes It is estimated that some 1 million Houses in Ireland are in need of upgrading to reach the BER standard A rating. Retrofitting these houses would:

• create employment in the depressed building industry, • address one of the underlying issues of fuel poverty, • dramatically reduce greenhouse gas emissions • and increase tax receipts

UK figures estimate an average cost of £25,000 per house for a full retrofit. Assuming a similar figure for Ireland, we are looking at a total of €25 billion at today’s prices. The proposal is to establish a system of rolling finance based on interest free loans to house owners to enable them to carry out the necessary work. The procedure would be as follows:

1. The house owner would agree with the lending body, possibly SEI, to get

the house retrofitted.

26 See the impact assessment and explanatory memoranda to the Carbon Emissions Reduction Target (CERT) programme available via http://www.defra.gov.uk/environment/climatechange/uk/household/supplier/cert.htm.


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2. The house owner would then request an assessment of the work needed to bring the building to the A-rating of the BER.

3. The BER assessor then carries out an assessment and calculates the energy saving per annum that will be achieved by the retrofit, based on current energy prices. The repayments of the loan are then set at that amount per annum until the total is paid.

4. The house owner would then be given a loan to cover the cost of the complete retrofit, which must be carried out in one go. The cost of the assessment would be included in the loan.

5. The loan would be set against the deeds of the house. The net financial effect being that the cost of the retrofit has no impact on the current expenditure of the house owner. Indeed as energy prices rise there will be a net saving. The occupier of the house will have a more comfortable home which has a much increased resale value. The above description relates to owner-occupiers, but it would be possible to adjust this for social housing. It is suggested here that a target of 40,000 houses a year would be an achievable target at an overall cost of €1 billion a year. In year one a good part of this would be needed to kick-start the project with focussed training, and supports to enable the gearing up of the relevant sectors of industry. Approximately €190 million would return to the government as VAT and perhaps another €100 million as income tax. This could either be used to fund other environmental projects such as public transport, or be rolled over into further funding for the retrofitting scheme for the next year. Approximately €50 million would be paid as interest by the scheme to the funding source. If the tax returns are rolled over, then the scheme will accelerate accordingly. In year two the borrowing could be increased if the capacity was there to do the work, and so onwards, and the repayments which would increase year on year could be fed back into the scheme. The source of the funding for this proposal could be one or all of the following:

1. Government Borrowing 2. Ethical Investment Funds 3. The Credit Unions


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Appendix II Land Value Tax

Now is the time to introduce an annual development land tax as part of reform of the rates system. The object is to raise the opportunity cost of not developing and so keep housing completion numbers at the 40 thousand per annum. This is likely to be supported by the Chambers of Commerce if linked to reform of commercial rates. Reform of rates to LVT (taxing land not buildings) will also stimulate reconstruction and refurbishment of commercial premises. The mere announcement of this measure will stimulate development.

Shift taxes from transactions on the narrow base of buyers (or sellers) to an annual land tax on all householders. Abolition of stamp duty alone, without a compensatory measure, would go straight to the seller to raise or at least halt the fall of house prices- for a time. This fall is a necessary correction. Secondly the government cannot forego the tax revenue and local government urgently requires funds for infrastructure and local services. A replacement tax on all home owners at a very modest .5%-1% per annum on the land element of their property can be sold politically as a ‘dig out’ for ‘the young first time buyers and trader uppers with children’ from those older homeowners who have seen huge rises in asset values (even with a correction). It can also be sold as gentle inducement for older people to trade down and liberate larger houses for families. Measures can be put in place to prevent hardship to senior citizens such as rolling up LVT to be paid by their estate after death. Announcing the intention to do this will not spook the market (as discussion of stamp duty reform did before the election) because the government would be taking with one hand and giving with the other. The effect on house prices would be broadly neutral in a naturally falling market. About 18 to 24 months is needed to prepare a land-value-scape after that reviews would be every year based on market information. Please note: • It is NOT rates nor a property tax - people will not pay more tax when they improve their property. It will stimulate renovation, extension and infill. • The LVT could be set against interest payments for owner occupiers who bought in the last, say five years, but not for new transactions - as for mortgage interest relief • Older people (over 70) can roll it up to be paid by inheriting family. • We should also promise that any further increase in LVT (in terms of its percentage) will be a TAX SHIFT against income tax or PSRI. Taxes on labour and capital dampen investment in these factors of production - the last thing we need in a downturn. But this is not true for annual taxes on land. This is the up-side of the fixed and pre-existing nature of land – in a virtuous circle, the higher the annual taxes on land, the more it is brought into production rather than the opposite.


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Appendix III Tree Cover Resources 1. In the short term, additional funds for the exchequer can be extracted from Coillte Teo by taking 30% of their profits annually to reinvest in forestry related road repair, training and work placement schemes, promoting thinning/pruning and use of small scale/low impact extraction machinery. 2. In addition selected Coillte FSC certified forests can be leased to a diverse range of stakeholder interests (who may be entitled to draw down grant aid - 40yr lease ), to generate additional revenue and also stimulate competition in the timber supply market and employment dynamic, where Coillte would cease to be the dominant employer of dependent contractors in the sector. Extensive leasing may obviate the need to retain the forest land management component of Coillte outside of the Forest Service, because the nature of monitoring the leases would be similar to the current remit of the Forest Service Inspectorate. 3. Those individuals who derive 25% or more of their income from tree cover activity and have the forestry equivalent of the agriculture 'green cert.' should, when purchasing land for afforestation, be entitled to the same level of annual premium as the farming community. 4. The potential of 272,000ha (NFI) of Hedgerows in the efforts to mitigate the impact of climate change, should not be underestimated. Because of technological advances in farming and forestry, the role and functions of hedges/ field boundaries is changing and becoming more significant. Training on the sustainable management of hedges and as extensions to existing forests, should be promoted by the Forest Service, in conjunction with Teagasc. Consequently, provenance certificates should be mandatory in REPS hedgeplanting as they are in grant aided Forestry, not least because this would significantly increase the market for Irish produced nursery stock, consolidating employment in that sector. 5. The Native Woodland Conservation Measure, which is currently bringing an additional c.1.5% of the unmanaged semi-natural woodland annually into operation as a source of carbon neutral fuel and future hardwood supplies locally, should be a permanent feature of any revised Strategic plan for the resource.


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Appendix IV COASTAL EROSION AND EROSION CONTROL With over 6800 km of coast and > 1 milion euro for new hard erosion control/100 m this is an area where ACTION 1: Halt all new erosion control funding ( ~ 15 million/annum) until we have a national erosion control policy. (Reasons and examples of present poor decision making and high cost available – synopses below box 1) ACTION 2: Maintain and restore existing erosion control wisely: SOFT COAST: Dunes are soft erosion control which is gratis, maintained by Nature if given the chance. Coastwatch review of 100 beaches in summer 2008 highlighted that we are not giving them the chance with serious vegetation damage widespread. Modern links courses which override natural dune movement were a feature of roughly half the beaches visited. Such dune use makes it highly vulnerable to erosion. Links grass has roots a few inches long, marram grass roots can be 10 feet long enabling it to withstand and recover from wind damage. Action: 2.1. Set strict obligations in place now to control all unnecessary use of public dunes which may damages the vegetation and increase vulnerability to erosion. This should include heavy on the spot fines and garda enforcement to stop bikes, beach buggies, horse riding, hunting, car racing in dunes. Give same support to private land owners whose generosity or old rights of way allows public dune access, so that it is not misused. ( NB - On Coastwatch side we will match that with publicity in a dune protection/use/abuse ranking summer 09. ) Action 2.2 Direct local authorities that no links course land can be developed or rezoned for development. It is likely that some links courses will fold in present economic crises. If they are turned into building land we have lost the sand dunes for ever and will be left paying for erosion control of houses or infrastructure which should never be built there, as soft coast is most vulnerable and needs to have the space to erode and recover. If golf club owners cannot sell for development, it is likely that the land will be sold as farmland and revert to extensive grazing if Natura 2000 site designation was restored. Win Win With restoration we can regain some of the (i) gratis erosion control and (ii) priority dune habitat. This would restore some of our poor dune habitat protection record and strengthen our green image. (iii) Moving to extensive grazing from intensive use golf links with mechanical mowing, high fertiliser and pesticide use and vehicles travelling to get there reduces the carbon footprint. SEAWALLS: Set up a volunteer seawall erosion monitoring and early intervention scheme. This vital infrastructure is often neglected until a major problem arises. Country bridges and old seawalls which typically protect sea roads used to be monitored 50 years ago. A missing stone is easy to replace. Once left until the next storm, the sea can create major damage, making the road behind the seawall impassable. The repair then undertaken by road crews carries a significant cost and is recouped from national government. Often locals lose a few days of work as they cannot get out and typically road crews use concrete to fix historic lime mortar build walls, leaving them ever more susceptible to further storm damage as well as destroying the integrity of historic features which we could be protecting and highlighting as attractions.


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While saving money by early intervention, we also believe that there is an opportunity to use existing EU funding available now for training to set up the monitoring of seawall and bridge status, and the skill to carry out smaller repair of old structures. Local ownership and participation strengthens the community and could be further expanded into ecoand educational tourism. Action 2.3 Use some of existing Leader money earmarked for training for training local landowners and road users to monitor seawalls and carry out small lime mortar repairs. Make inventories of seawalls and local piers and harbours as part of training exercise. Set up voluntary monitoring crews and feed back data from these crews as part of national erosion policy and implementation. Action 2.4 Link and boost local expertise, knowledge and tourism. Facilitate application of local knowledge and expertise for use in eco and educational tourism of our coastal zone - integrate with Failte Ireland. Box 1: Background: At present there is no overview of what get funded, no public scrutiny for schemes which are under OPW or labelled ‘emergency’ and no cost benefit analyses. Some schemes are of short use as the sea will take them away again – e.g. access at Clogga Beach Co Wicklow. A few months ago the OPW completed a major seawall reinforcement at the Cull Wexford, without local authority or public knowledge. The scheme which cost> 1 million secures extensive farmland. A farmer 5 miles on may loose his farm access as the sea road is falling in valuable top quality soil but no one will help, a dune will be studded with rock ajrmour as a T may be under threat. Cost are > 100 000 per 100 m for most hard erosion control schemes. There is a perception that those who shout loudest like golf clubs are most likely to get erosion control, while people who work with nature are not respected or thanked. Some of the best high value dunes are expertly managed by farmers in commonage – e.g. Mullaghmore, Co Sligo. They get absolutely no thanks for it and not a cent extra for their sheep or cattle.

two major crises facing government

Documents

environmental pillar

environmental resources

government submission

environmental services

environmental sustainability1

irish government

low carbon economy

wider economy