Our greenhouse gas emissions in Tipperary are staggeringly high. We have higher per capita emissions than any other country in the EU, higher than China, Russia and the USA. If Tipperary were a country, our per capita emissions would be one of the highest in the world, ranking alongside the worst-polluting petrostates:

Country data from Our World in Data and includes LULUCF. Co. Tipperary per capita emissions derived by dividing the total emissions (3 703 400 tonnes) by the preliminary population for 2022 noted in the draft Climate Action Plan (167 661).

The publishing of total emissions for County Tipperary in the draft Climate Action Plan is welcome, however it is difficult to understand the figure of total emissions of 3,703.4 kt of CO₂eq (the unit of kilotonnes is missing from page 32) without providing some context. I would like to suggest that some more context is given in the final version of the plan, possibly with international comparisons like in the table above, illustrating that if the rest of the world was as polluting as our county, the world would have a few short decades left before most of it became inhabitable.

Agriculture

The 7,404 farms in Co. Tipperary (CSO, 2022) are the source of 1,849 kilotonnes of CO₂eq emissions. 90% of Irish beef and dairy produce is exported. I would like to suggest that actions be developed with the Local Enterprise Office and other agencies to support greater value-added processes in Tipperary, perhaps following the success of products such as Cashel Blue cheese, to encourage a shift away from exporting internationally-traded commodity products such as Skimmed Milk Powder, and towards a more premium product that can potentially provide a better return to farmers. There are currently over 100 organic farms in Tipperary (Farmers Journal) and I would like to suggest that a market development programme for organic produce be developed in the county to help existing organic farmers to find a market for their produce which may also encourage conventional farms to convert to organic (and which would result in a reduction in agriculture emissions due to lower stocking rates on organic farms).

Transport

Tipperary County Council is the roads authority for all public non-national roads in the county, in addition all the permissions for the recent expansions of the national road network in the county – for example the M7, M8, N24 and N52 – were applied for by Tipperary County Council and its predecessors, despite being funded by Transport Infrastructure Ireland and predecessor agencies.

The Environmental Impact Statements for the major road schemes in the county presented by the Council all showed a ‘steady state’ volume of traffic, the new roads schemes, many of which bypassed towns, were predicted to simply divert traffic away from the towns with little or no net increase in traffic. Unfortunately this did not turn out to be the case and volumes have significantly increased on the road network, especially on motorways, far in excess of national roads elsewhere in the country that did not see improvements. This has been a contributor to the rise in transport emissions in Tipperary.

I would like to suggest that an action be added to the Climate Action Plan that Tipperary County Council perform a retrospective evaluation of all major road schemes developed in the name of the council over the past few decades, including the road schemes mentioned above, to evaluate the climate impact of these schemes (by comparing the increase in traffic volumes along the corridor of the schemes with other national roads elsewhere in the country that were unimproved), which appears to have been significantly underestimated in the Environmental Impact Statements produced by Tipperary County Council in ‘support’ of the schemes. Such a retrospective evaluation could improve future Environmental Impact Statements and better inform the development of future road programmes. An example of such an evaluation on the carbon impact of new road schemes in the UK is available from Transport for Quality of Life (PDF).

I would also like to suggest that a fresh analysis of the induced demand potential of all road schemes proposed in the county development plan and local area plans be performed to evaluate the negative climate impact of facilitating more traffic in the county, preferably assisted by the analysis suggested above. Recent urban traffic schemes, for example the recent Section 38 permission obtained by Tipperary County Council to expand capacity for private cars in the centre of Nenagh with a two-lane one-way system was not published with any analysis of traffic or emissions impact, and suggestions in the public consultation process to change the scheme to allocate space for more sustainable transport modes such as walking and cycling were not taken up.

Finally, I would like to suggest an amendment to the action on transport hubs: to change the wording from Support the delivery of an ‘Integrated Transport Hub’ in the Key Towns of Clonmel, Nenagh and Thurles to incorporate and support multi-modal services… to Support the delivery of an ‘Integrated Transport Hub’ in the Key Towns of Clonmel, Nenagh and Thurles to incorporate and support multi-modal services while supporting the maintaining of the existing public transport stops in the centre of these towns… in order to make sure that current and prospective public transport users are not inconvenienced by the moving of bus stops to more peripheral locations to facilitate private car traffic, as has recently been proposed in Nenagh.

While I think there are other areas worthy of inclusion in the Climate Action Plan, in particular around settlement patterns and one-off housing and the greater facilitation of solar and onshore wind, the main point I would like to make is that there is a lack of urgency in the draft. This year the World Health Organisation said that Life-threatening hunger caused by climate shocks, violent insecurity and disease in the Horn of Africa, have left nearly 130,000 people “looking death in the eyes” and nearly 50 million facing crisis levels of food insecurity. We need to acknowledge that Tipperary is contributing to the problem of climate change far in excess of Irish, European and global norms and we need to take real action to reverse some of our mistakes and to take responsibility as a wealthy and prosperous county to right some of the wrongs we are inflicting on the world.

Thank you for the opportunity to make a submission on the draft climate action plan. This submission is made on a personal basis and does not represent the views of any other organisation, including my employer.

Local Area Plan

I have a general comment about the pattern of development of Nenagh, and that is that the focus of development in Nenagh appears to be at the edge of the town. Recent housing developments in Drummin Village and the Fiserv building on the Limerick Road are two examples of recent developments that, while welcome from the perspective of housing and employment respectively, are located quite a distance from the town centre and are designed to be primarily accessed by private car. The traditional layout of Nenagh is compact and sustainable, but these recent developments have served to undermine this. I worry that the pattern of zoned lands in the Local Area Plan will continue to support sprawl at the edge of town, especially as Greenfield development will be cheaper for property developers than building on any of the brownfield sites identified in the Local Area Plan.

A recent local newspaper article about the proposed digital hub on the Rialto cinema site quoted a local authority official saying “It had been planned for Stereame but that had been shot down by the Department as it was not town centre”. The bias towards out-of-town development has worrying implications for the future sustainability of the town and goes against many national, regional and county-level policies on consolidating our town centres and the principle of compact growth. I do not know what specific measure in the Local Area Plan could help counteract this bias, but perhaps it would be helpful to engage with local authority officials who view locations like Stereame as suitable for digital hubs and software development companies, to see what guidance would encourage them to site (and encourage others to site) such developments in the town centre. Certainly the descriptions of the Stereame and Lisbunny sites in the Local Area Plan leave the reader with the impression that the development of large-scale employment is not encouraged within the town centre (or in locations where employees could comfortably walk into town on their lunch break), notwithstanding the principle stated that new offices should have easy employee access.

A lot of land in Nenagh is given over to car parking, both on-street and off-street. I would like to propose a specific opportunity site in the Kenyon St car park. The car park already has recently-built commercial units at its far end, and replacing the car parking with a mixed housing/employment development, with additional permeability for active travel towards Silver St and Stafford St, would be a positive development for the town. Any need for more parking displaced by the closure of Kenyon St car park could be accommodate on sites further out of town.

Local Transport Plan

It is difficult to see the rationale for the “Nenagh Traffic Management Plan” which was submitted as a Section 38 development four months before the Local Transport Plan was released. No traffic modelling, road safety audit, or any other narrative document was made available with this traffic management plan, it was just a set of drawings. The Local Transport Plan just seems to accept the introduction of this plan, accompanied by a statement “Over the longer term horizon of the LTP, further enhancements to the proposed one-way system may be feasible through reallocation of road space for public realm upgrades and further provision for active modes”, which is a relatively weak commitment compared to other measures proposed in the plan.

The problem with this traffic management plan is that it creates a severance in the middle of Nenagh for active travel users. Some footpaths covered by this management plan will be under the DMURS minimum of 1.8m in width, and cyclists will have to navigate dangerous two-lane one-way streets. I live on Sarsfield Street, we have two boys aged 7 and 10. The new traffic management plan will negatively impact on our ability to encourage independent mobility for these kids. For example, I take the 7 year-old to swimming lessons in the council swimming pool by the town park. We were just getting to the stage where we were able to cycle on the road for part of the journey to the pool. I don’t think it will be safe for me to cycle with him in the new layout: we would be forced to try and navigate two lanes of cars going the same direction, with no facilities at all to help him make his journey through the town centre. Equally I was hoping that it would be possible for the boys to cycle themselves to the train station in the future: that journey will be made much less safe as a result of the traffic management plan, and may prevent them making this journey at all.

Furthermore, the aim of the Nenagh Traffic Management Plan is stated in the Transport Plan to “reduce congestion” which is another way of saying “increase capacity for the private car”. I don’t believe this is compatible with the national, regional and county-level commitments to reduce emissions and reduce dependency on the private car.

I would like to suggest a new measure to try and ensure that the redesign of this facility is encouraged as a priority:

ATx: Priority reallocation of road space on the new Nenagh Traffic Management Plan towards active modes to provide safe segregated routes for active travel users and to mitigate against the increased capacity for private cars being introduced in the town centre.

Active travel network

Aside from the severance in the town centre caused by the Nenagh Traffic Management Plan, I would like to welcome the active travel network proposed. If implemented over the period of the plan it would have a positive effect on the town, especially for the 1 in 5 households in Nenagh who do not own a car (Census 2016). Some of the visualisations in the Plan are excellent with bevelled entrance kerbs and no height change for pedestrians and cyclists crossing side entrances. It might be worth incorporating these design elements as a specific action for any new measures built, to avoid the usual ‘dipping’ of footpaths at side entrances and severance of cycle facilities at junctions.

Public transport network

The transport plan does not propose to remove the town centre bus stops and I would like to welcome this measure. The narrative in local media from council meetings quoting local authority officials that I have read emphasised that buses were getting in the way of cars. I never saw any discussion reported on how more people can be encouraged to use public transport. I have reservations about the proposed mobility hub, in light of the above, but as long as buses are stopping in the middle of town where services are accessible to more people, some additional rail/bus integration may be helpful.

Roads

The proposed roads do not seem to meet the criteria for new roads outlined in the local transport plan. I could not see any specific mitigating measures being proposed that would counteract the induced demand for more traffic as a result of such schemes. I would support the HGV ban, although I do not see the building of additional roads as necessary to facilitate this ban.