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Environmental Pillar Submission on the McCarthy Report

Environmental Pillar Submission on the Report of the Special Group on Public Service Numbers and Expenditure Programmes (McCarthy Report) 14th October 2009

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Environmental Pillar Submission on the McCarthy Report

Contents 1

Summary............................................................................................................................................................... 3

2

Introduction......................................................................................................................................................... 4

3

Context .................................................................................................................................................................. 4

3.1

Towards a truly Sustainable Society .......................................................................................................... 5

3.2

Resilience ....................................................................................................................................................... 6

3.3

Objectives ...................................................................................................................................................... 6

3.3.1 3.3.2 3.3.3

Common Purpose..................................................................................................................................... 6 Security...................................................................................................................................................... 6 Realism about Ecological Limits............................................................................................................. 6

4

Cross Cutting Issues ......................................................................................................................................... 6

5

Specific Responses to the Report ................................................................................................................ 9 Section 1.3 Other Key Issues .......................................................................................................................... 9 Section 2.9 Public Procurement....................................................................................................................... 9 Section 2.11 Outsourcing of Government activities and Section 2.12 Shared ICT services ............... 10 Section 2.13 Performance Impacts and Value for Money ......................................................................... 10 Sections 2.14 – Rationalisation of state agencies....................................................................................... 11 Section 3.1 Agriculture Fisheries and Food ................................................................................................. 11 Loss of agri-environments scheme funding................................................................................................. 12 Section 3.2 Arts Sports and Tourism ............................................................................................................ 13 Section 3.3 Department of Communications Energy and Natural Resources......................................... 13 Section 3.4 Dept Community, Rural and Gaeltacht Affairs........................................................................ 14 Section 3.5 Defence ........................................................................................................................................ 14 Section 3.6 Education and Science ............................................................................................................... 15 Section 3.7 Enterprise Trade and Employment........................................................................................... 15 Section 3.8 Environment, Heritage and Local Government ...................................................................... 15 Departmental responsibility changes............................................................................................................ 16 Detailed Paper 8. Para E2 (of Volume II) .................................................................................................... 17 Section 3.10 Department of Foreign Affairs ................................................................................................ 18 Increase in Overseas Development Aid (ODA) ...................................................................................... 18 Education for Sustainable Development ................................................................................................. 19 Section 3.17 Department of the Transport.................................................................................................. 19 Sale of Bus Eireann Expressway: ............................................................................................................. 19 Disposal of land/property holdings: ......................................................................................................... 20 Road Pricing: ............................................................................................................................................... 20 Proposed Discontinuation of the Green Schools Initiative and the Rural Transport Programme:.. 20 Removal of the PSO Subsidy for Regional Air Services: ....................................................................... 20 Rail Line Cuts: ............................................................................................................................................. 21 Merging of QUANGOs: ............................................................................................................................... 21

Whilst this document was developed through the processes of the Environmental Pillar it does not necessarily represent the policies of all its members.

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Environmental Pillar Submission on the McCarthy Report

1 Summary Ireland faces two major and interlinked crises, firstly an environmental one and secondly an economic one. Whilst it is clear that a very serious economic crisis is upon us, with unfortunately many thousands of people unemployed, the consequences of rapid climate change and general environmental degradation are likely to be far worse. It is essential then that in dealing with the economic crisis the government applies the principles of sustainable development as described in Agenda 21 in all its decision-making. None of the recommendations of the Report should be acted upon without first assessing the environmental consequences of that action. This should be done using the processes of Strategic Environmental Assessment laid down in the EU Directive 2001/42/EC, even where it is not required under the Directive. This should be done as a participatory process as provided for in the Aarhus Convention. This submission begins by setting the Report and its recommendations in the broader environmental, social and economic context. It then looks at the crosscutting issues relating to the recommendations, following this with a section by section response to the body of the Report. Our economy needs to focus strongly on creating resilience to the outside forces of global change. In this context our government structures must support sustainable management of our natural resources to strengthen food and energy security and mitigate the impacts of climate change. Fundamental to this is the need to employ for example land use grants to promote carbon sequestration, sustainable forestry and farming, flood mitigation and indigenous food production. By protecting our terrestrial and marine natural infrastructure jobs will be created, imports reduced, energy saved, and the economy strengthened for both the long and short term. It is the position of the Environmental Pillar that as decisions are made by government on each of the proposals for change suggested by the Report each decision must take into account the issues of sustainability alluded to above and described in more detail in the body of the submission.

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Environmental Pillar Submission on the McCarthy Report

2 Introduction The Environmental Pillar recognises the thorough way in which the authors of this report fulfilled their remit within the given terms of reference, and welcomes this opportunity to input into the deliberations of the Joint Committee on Finance and the Public Service. It is the Environmental Pillar position that there are two crises facing the country, one the economic and the other the environmental. In considering one it is essential to include the other. The terms of reference given to the authors of the Report ignore the fact that our society grew out of the environmental context on which it is entirely reliant, and our financial system grew out of our society, and that they are all three inextricably linked. Further it is the environmental services that provide the essentials for human society in the form of clean water, good soils, clean air, and it is the uncontrolled exploitation and degradation of these services that has created this overriding environmental crisis that we all now face. The terms of reference do not include a consideration of the requirements of environmental sustainability and as a consequence the report ignores the wisdom of the multi-faceted analysis that led to the formulation of the model of Agenda 21 in 19921. Taking this into account it is essential that in the context of the rapidly accelerating environmental crises, caused in major part by climate change, none of the recommendations of the McCarthy Report are acted upon without a proper Strategic Environmental Assessment (SEA) being carried out on each of the relevant programme areas. This submission addresses the report section by section, but the comments made are provided with a context in the next two chapters.

3 Context The collapse of the world economy and Ireland’s particular condition within it present profound and immediate challenges both to the Irish Government and the Irish people. In addition, with our national focus on crisis management we are failing to engage with the near-to-medium term risks of an energy-induced systemic crisis that will dwarf the current economic crisis in both consequences and complexity. In the meantime, the risks associated with climate change are rising, and at the same time our effort to manage those risks is under increasing strain. There are then two crises facing the government. In responding to the McCarthy Report, this submission attempts to address these looming and overarching risks to our future as a stable society with a functioning economy based on sustainable practice. This requires a deep-rooted understanding that the concept of an unrestricted growth economy is what has got us into this predicament, and only by 1 Agenda 21 addresses the critical issues we face as a global community: continuing damage to ecosystems, the worsening of poverty, hunger and ill health, increasing world population and illiteracy. Agenda 21 is composed of 40 chapters that identify each challenge and propose simple realistic solutions towards sustainable development which is defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

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Environmental Pillar Submission on the McCarthy Report

moving to a sustainable2 model based on an ecosystem management approach3 can we have hope for the future. You cannot fix a problem using the very tools that caused the problem in the first place.

3.1 Towards a truly Sustainable Society Short term measures to stabilise the economy by perpetuating the current global economic model are failing due to an inherent fault in this model. This can be summarised as follows: •

The current economic model is one in which finance is based on debt and interest payment on this debt.

Servicing this debt requires a continuous expansion or growth of the economy.

All economic activity is ultimately based on extraction and manipulation of natural resources for raw materials and energy.

Since we live on a finite planet with finite resources, infinite growth that surpasses the resources of a finite planet cannot be maintained and it is therefore a matter of ‘when’ and not ‘if’ the current model fails. A model based on unrestricted economic growth that relies on the depletion of our natural capital and threatens our ecosystem services4 is just not sustainable. Radical times require radical solutions and the Environmental Pillar urges the Government to place the decisions regarding any implementation of the McCarthy Report into a global systemic perspective.

2 Sustainable development is maintaining a delicate balance between the human need to improve lifestyles and feeling of well-being on the one hand, whilst preserving natural resources and ecosystems, on which we and future generations depend. "Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs" Bruntland definition 3 An approach to natural resource management which aims to sustain ecosystems (see glossary) to meet both ecological and human needs in the future

4 The benefits people obtain from ecosystems. These include provisioning services such as food and water; regulating services such as flood and disease control; cultural services such as spiritual, recreational, and cultural benefits; and supporting services such as nutrient cycling that maintain the conditions for life on Earth.

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Environmental Pillar Submission on the McCarthy Report

3.2 Resilience Our economy needs to focus strongly on creating resilience to outside forces of global change. In this context our government structures must support sustainable management of our natural resources to strengthen food and energy security and mitigate the impacts of climate change. Fundamental to this is the need to employ for example land use grants to promote carbon sequestration, sustainable forestry and farming, flood mitigation and indigenous food production. By protecting our terrestrial and marine natural infrastructure jobs will be created, imports reduced, energy saved, and the economy strengthened for both the long and short term.

3.3 Objectives This submission looks at the McCarthy Report proposals in the light of the above. 3.3.1 Common Purpose The Pillar recognises that in times of increasing social stress there is need for policy that cultivates social cohesion and common purpose through fairness and transparency. There is an understanding here that whilst economic stability is essential, the development of sustainable communities where people have a good quality of life should be the central aim of the policy. 3.3.2 Security Any actions taken in the context of McCarthy must aim to support human security in all its facets, including economic, physical, and environmental. A creative vibrant society needs all these aspects to be protected. 3.3.3 Realism about Ecological Limits Any actions taken in the context of McCarthy must take into account the fact that human welfare, the economy and civilisation, are on the cusp of major change arising from the unsustainable use of environmental resources and sinks upon which they depend.

4 Cross Cutting Issues The Environmental Pillar is disappointed to see that the authors did not include sustainability with the emphasis on environmental sustainability in its ‘cross cutting’ issues and themes. Short term savings should never be permitted to undermine long term resilience. This omission has led to conclusions and recommendations in the report with which the Environmental Pillar has serious concerns. The Environmental Pillar notes that the authors identify policies for ‘public goods’ which are provided out of general taxation but ‘commons goods’ such as water, atmosphere, land, biodiversity and environmental services are not given equal and due attention. This

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has led to the conflation of public goods with commons goods in the Report leading, for example, to the suggestion that the land and forest resources of Coillte, a commons, should be privatized. The Environmental Pillar holds that commons goods should never be privatized but protected in trust for all current and future generations. The central thesis that government must issue debt (or borrow in other words), to fund public services and investment is not explained but assumed as a given. This does not acknowledge that in these extraordinary times, governments and financial institutions generally have been forced to explore funding mechanisms that they would not have countenanced before. There are new forms of non-debt financing such as Limited Liability Partnerships that are asset-based in which parties share the upside or downside of the gross income equally according to their percentage share. More pertinently, the government of Iceland has agreed a repayment plan to foreign depositors in their failed banks according to a formula based on GDP and not a simple interest rate. The debt-based origin of money underpins much of the growth imperative and explains why when growth stops, the impact on money in circulation or the ‘liquidity crisis’ is so devastating for the ordinary economy. The Report identifies pensions as having a major impact on current expenditure. It points out the relatively high level of pensions enjoyed by the public sector, particularly the flexibility and ‘added years’ perks that civil servants routinely enjoy. We agree that the levels of pensions based on final salary plus the practice of top-ups are extraordinarily generous and ought to be reduced but we disagree that the ‘unfunded’ nature of pension is problematic per se5. The Environmental Pillar holds that investment in funded pensions for retirement is a misnomer; pension ‘savings’ is a more accurate term than ‘investment’. Public pensions of retired civil servants are paid by the taxes of working public sector workers and working private sector workers. This is, contrary to common opinion, an efficient system but it is unfair insofar as private sector workers do not enjoy the same kind of pensions as the public sector even though they pay the same taxes - recent changes not withstanding. The Environmental Pillar favours universal systems that cross or blur private/public differences. Guided by this principle, we prefer a basic substantial non-contributory pension topped up by a single state contributory pension open to public and private sector worker alike and funded by savings and genuine investment in new productive infrastructure such as local renewable energy. This genuine investment would come from the capital side of government expenditure thus reducing impact on the current side. The Environmental Pillar can see the efficiency of the amalgamation of the plethora of enterprise support agencies to reinforce the gateways centres identified in the National 5 . In fact public sector workers pay an average pension contribution of 12% and full PRSI (for those entering the public service since 1995).

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Spatial Strategy. This would reduce the urban - rural policy approaches which does not always offer support to all equally. However, we would be concerned that the recent participation of the environmental sector is continued and that the focus on biodiversity protection sustainable energy, food production and environmental services which is part of the current Leader programme is protected and strengthened. With amalgamated agencies, transparency and accountability will become even more important. In this context the ratification and implementation of the Aarhus Convention and the broadening of its provisions to all aspects of governance are essential. Universal systems such as citizen income/dividends would reduce the poverty traps and disincentives to seeking and accepting employment identified by the Report. Targeted voucher systems for job training or for the delivery or other services at local level would allow greater competition between public/private/ and the voluntary sector agencies and less intrusive oversight by various government agencies. This would have the benefits of a demand-led system rather than one which is supply-led, similar to recommendations of the Centre for Housing Research/Grant Thornton Report on funding system for Voluntary and Co-operative Housing. The Environmental Pillar cannot help but note that while competition is seen as positive in the private sector it is seen as overlapping inefficiency in the voluntary sector. Voucher systems get over this anomaly and we urge the government to consider such systems as they preserve the considerable benefits of local knowledge and flexibility of response. Accordingly, we do not support any of the proposals of the Report to reduce or rationalize voluntary sector delivery of social support in their current form. Public procurement should bear in mind the need to build resilience as part of the overriding aim of delivering sustainability. Resilience requires that environmental considerations should be supported in procurement policies, particularly energy and climate change objectives. That means for instance that local food and low energy /carbon should have an advantage. Price alone can be deceptive as a guide towards medium and long-term value for money. Property held by state agencies is often used inefficiently. Selling property in the current downturn is not the way to resolve this. It is likely that such a policy would likely deliver bad value for the taxpayer. The introduction of an annual land value taxes should be applied to state property, as to all other private and charitably owned land and sites in Ireland. Such a system would over time encourage state agencies and local authorities to use their property efficiently or to let or sell it to those who could put it to better use. It should be noted that public agencies do not have a definitive record of what they own as Ireland, alone amongst developed nations does not have a complete register of property and its ownership (cadastre). Neither does it possess a ‘map-based’ system of registering property with fixed or absolute boundaries. The report should advise the government to rectify these omissions before it demands the sale of public property assets or it could be selling more that it bargains for. Cost benefit analysis would be enhanced by annual land value mapping as value created anywhere in the economy by public or private actors attaches inexorably to adjacent land Page 8 of 21


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and sites. Therefore central and local government policies that add value can be readily identified. An annual land value tax would automatically reward effective public authorities and policies. It would also remove all speculative value of land and consequently, all incentives for planning corruption and investment in property development over investment in productive businesses. The case for outsourcing activities is well made. However, such outsourcing should not be offshore, and the Report is silent as to where the offshore services should be sited. All capital projects should be subject to a Strategic Environmental Assessment including land valuation; upswings in annual land value taxes due to such investment should be captured to help pay for the capital projects. Where the projected land values do not increase, it is evidence that the project should not proceed. It should be a matter of principle that no one should be paid more than 10 times the entry level salary in that organisation. Government needs to examine the cost effectiveness of employing very expensive large consultancies when there are many small indigenous consultancies and voluntary sector bodies that could perform many of the same activities as well and sometimes better for far less outlay.

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Specific Responses to the Report

In this section the commentary follows the structure of Volume I of the Report. Section 1.3 Other Key Issues All decisions regarding capital expenditure should be subjected to a Strategic Environmental Assessment Section 2.9 Public Procurement In Ireland, the total Government and public sector purchasing power is over â‚Ź10 billion per year, which gives it great leverage to direct and affect the commercial marketplace. Each governmental department, in order to lead the way in sustainable development, should adopt green policies both within the departments and when tendering for commercial contracts. Because the purchasing power of the Irish government is so immense, green public procurement (GPP) can make a tremendous contribution in changing the public and commercial view towards a more sustainable method of production and consumption. Currently, procurement contracts are normally awarded to the bidder who scores the highest on certain variables set out by the governmental entity. Unfortunately, the environmental costs or savings are not calculated into this formula. The government must take a more sustainable position when putting out tender offers and consider the life cycle costs (LCC) of potential bidders. There is a misconception that green products and services are more expensive. However the results of the LCC

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analyses regarding price differences between green and non-green products illustrate that there is really no economic difference between the two approaches. The production, energy consumption, packaging, transportation and disposal costs must be considered, among other environmental factors, when analyzing all competing tender bids. To achieve this, the criteria developed for ecolabels (European and national) should be synchronised with the public procurement process. Where there is a product generated under an accredited certification scheme rather than an ecolabel, these should also be considered. An example of such a certification scheme would be the Forest Stewardship Council (FSC) Certification Scheme for timber and timber products. Given the large volumes of stolen timber imported into Ireland it is essential that any timber or timber products used by local and national government is certified. The government has an incredible economic sway to ‘move the market’ towards more environmentally sound goods and services and towards a more sustainable commercial marketplace. Rigorous transparent and verifiable Due Diligence (DD) procedures must be set up by Irish timber traders/industry and supported by Government to ensure they do not feed in to the illegal-logging trade6. The Green Procurement programme developed by the Swedish Government would be a good role model to start with7.

Section 2.11 Outsourcing of Government activities and Section 2.12 Shared ICT services The total monies paid to contractors and consultants often bear no relationship to the original contracts. This may be due to the way in which contracts are drawn up, or a lack of thought in the planning of the projects. The requirement to conduct a full Strategic Environmental Assessment or Environmental Impact Assessment, depending on scale, would provide a clear structure in which to research a project fully, as well as protecting the environment. The way in which projects/activities are put out to tender as well as the tendering processes themselves reduce the opportunity for small indigenous companies or organisations to compete. Section 2.13 Performance Impacts and Value for Money Each governmental department must endeavour to conduct an environmental and energy audit of its buildings to ensure that it is leading by example. Segregated bins for recycling and composting, energy-saving office equipment, automatic power-down of equipment and lights when not in use, staff training on adopted environmental management systems 6 The Central Point of Expertise on Timber Procurement (CPET) http://www.proforest.net/cpet 7 http://www.msr.se/en/green_procurement/Swedish-National-Action-plan-for-GPP/ [accessed 13/09/2009]

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should all be adopted by the government on a national and local level. Educating staff on office environmental and energy measures will have the knock-on effect of affecting their actions at home as well, leading to substantial economic and environmental savings in both the public and private sectors. Sections 2.14 – Rationalisation of state agencies As with all the proposals in this Report there is little evidence of long-term strategic thinking. All rationalisation decisions must be subjected to a Strategic Environmental Assessment. Section 3.1 Agriculture Fisheries and Food The Environmental Pillar broadly supports rationalization of agencies and of office locations in this sector, however, it considers that the proposal to “dispose of nonessential land/property holdings owned by the State Agencies;” is not a good one at this time. In the light of the proposals regarding the review of forestry in the “Renewed Programme for Government”, the issue of funding the expansion of forestry as part of the Rural Development Programme should be revisited. There should be no disposal of state forestry lands, especially Coillte lands at any time. Rather than disposing of these lands, as is currently happening, albeit at low levels, there should be no further disposal of Coillte lands, which should instead be managed for carbon store and sequestration which will in the very near future (2010) be economically beneficial under global climate agreements. Coillte lands and forestry are a huge asset to this country, especially in terms of: meeting future domestic timber needs; providing future valuable state carbon stores and sequestration; provision of valuable ecosystem services and climate change adaptation; and recreation and amenity. The Environmental Pillar will strongly oppose any attempts to privatise Coillte or its landholdings. The businesses trading under Coillte umbrella are quite a different matter and could be sold as businesses as the case for public ownership is not convincing. The proposal to “review the operations of Coillte with a view to realising optimal return through rationalisation, asset disposal and, possibly, privatization” needs to be more closely examined. Any review should look at improving its performance on environmental and social as well as economic grounds. An alternative to disposal would be the leasing the state forests to a variety of concessionaires, including individual forest workers, local authorities, community groups and commercial operators would open up the sector to competition - with strict covenants on sustainable management, protection and report back. This would also allow for the development of local industries and renewable fuel supplies. Leasing is cheaper for new users of such property than purchasing, and releases more funds for productive capacity, as well as providing the state with a long-term income stream.

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The lands would retain current public amenity and access. The terms of the lease would be 'Sustainable Forest Management' as agreed between the Forest Service (the regulator) and the various stakeholders. This would generate revenue for the exchequer, set at a rate that covers the cost of lease management plus a return on the underlying land value. Other possible benefits of there being a diversity of lease holders include: Economic: the development of a competitive market for timber supply. Social: more micro management, leading to increased rural activity. Opportunities for younger foresters to 'life cycle' with sites Ecological: more structural and species diversity. Strengthen the human<>tree-cover bond and culture. This would need simple supports in training: a one year Tree cover/Forestry Cert similar to the farming Green Cert. In tandem qualified Forest operators need an upgrade to a par with Farmers in relation to grant and premium entitlements and the hiring of casual labour, in order to attract people into the sector and to add to the viability of leasing public lands. Loss of agri-environments scheme funding Previous submissions made regarding the loss of funding in this area and proposals for a new agri-environment fund are to be found at: http://www.environmentalpillar.ie/?p=272 along with submissions regarding the RDP. These submissions are to be seen as an integral part of this submission. The structure of a new scheme, developed in consultation with environmental NGOs that is capable of meeting the varied objectives and challenges of agri-environment schemes is outlined in our previous submission which is a useful starting point for developing this process, to benefit the environment, farmers and rural communities in Ireland. The Environmental Pillar agrees that “the operation of the TB and Brucellosis Eradication Schemes be reviewed for efficiency and effectiveness”. This is important as there is much evidence to suggest that the ‘culling’ of tens of thousands of badgers each year, as carried out under this scheme, has little impact on TB levels in cattle as the badgers are not responsible to infecting cattle in the first place. The vulnerability to TB has more to do with the health and thus resilience of the animals than the presence of badgers. Many in the environmental sector would welcome this scheme being axed. It is very important that regulatory obstacles to new activities bringing green jobs and income to rural areas be fully justified. The EP believes that regulations governing anaerobic digestion in rural areas are seriously unbalanced relative to other EU member states. The regulatory environment is tailored to large-scale urban-based organic waste facilities, which bring unrecognised negative impacts of their own. Regulations and planning guidelines that foster rural anaerobic digestors, as per Teagasc recommendations, are all that is needed to inject millions of euro of private investment into rural areas. The same issues are preventing the development of appropriate scale rural systems, such as pyrolysis, to process dry organic waste.

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Section 3.2 Arts Sports and Tourism The Environmental Pillar generally supports rationalization of these sectors which are a big source of patronage with all that that implies. Demand-led rather than a supply-led funding is to be preferred. Voucher schemes issued to individuals and communities for arts, sports and culture would allow for competition between the public, private and voluntary sector delivery agents and would require considerably less oversight by public agencies. Thus more of the money allocated would get to the artists/sports people and less would be siphoned off by the growing ranks of administrators. Section 3.3 Department of Communications Energy and Natural Resources The Environmental Pillar agrees that the management of inland fisheries should be moved to the Department of the Environment as part of the rationalisation required under the Water Framework Directive. The River Basin Districts are well placed to monitor water quality (including fisheries) for both biodiversity and sustainability as a resource for production and human consumption and should be considered as trustees of these commons by local authorities as part of this reform. The merging of the OSI, Valuation Office & Property Registration Authority is badly needed and would be supportive of the development of the Site Value Tax in the Programme for Government The Energy Efficiency Programmes should be rationalised and include a mass retrofit of all domestic properties as outlined by the Pillar in its paper “Tackling the Two Crises facing the Government”8 so promoting future decarbonisation and employment. The Environmental Pillar agrees that the energy companies should shoulder the responsibility for promoting energy awareness and the gradual running down of the programmes run on this by DoCENR and Sustainable Energy Ireland. This is a very valid suggestion. The point made in the report rightly states that “…the benefits are already well appreciated by consumers and energy prices are a stronger determinant of consumer behaviour.” This most definitely is a justifiable cut in comparison to many others in different sections of the report. The carbon tax regime will get the same results as the many grants systems without the cost and public oversight. We would go further to suggest that a very high carbon price, raised by either a tax or a cap on fossil imports would achieve even more. The Pillar recommends that carbon taxes /caps receipts do not go into the general government pot but are hypothecated; 70-80% to be distributed to citizens equally and 20-30% invested in infrastructure for distributed energy and climate adaptation. Cap and Share is more effective than taxation alone as the price of carbon can be raised quickly and predictably speeding the shift to a low carbon economy, with the poor being automatically protected.

8 http://www.environmentalpillar.ie/?p=63 [Accessed 13/10/2009]

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The Pillar also agrees with the need to rationalise the multiplicity of energy efficient schemes run by SEI. The atmosphere can be understood as a commons good and therefore the use of its capacity to absorb CO2 should be charged for and the receipts redistributed to the beneficiaries of the commons. Such a charge is not strictly speaking a tax and, similarly to land value taxes (LVT), is more correctly described as a rent or charge for the use of commons goods. The proposal to “Transfer energy research funding to a new single funding stream for all research” is not a good one. Already energy research is at a very low level in this country. Now is the time to elevate the energy sector to top-line focus as it is one of the major areas which will assist our economy to recover in a long-term sustainable fashion. Transferring funding in this manner will eliminate the support it needs to develop as a lead sector in Ireland. The Environmental Pillar fully supports the merging of Ordinance Survey Ireland, the Valuation Office and the Property Registration Authority. This should help speed the development of a proper cadastre and GIS boundary registration system for Ireland. It is important that spatial information gathered over generations is recognized as a commons good and not commercialised. Reforms must ensure that up-to-date Ordinance Survey maps, property ownership, market prices and valuation information is publicly available and easily searchable at an affordable cost. Auctioning of long-term rights to the electro-magnetic spectrum is not acceptable as these are commons goods owned by the people of Ireland and must be held in trust for future generations. Auctioning of leases of parts of the electro-magnetic spectrum for limited terms is acceptable, subject to rents that are reviewed periodically without automatic rights to renewal. Section 3.4 Dept Community, Rural and Gaeltacht Affairs Funding for local community development and environmental sustainability should come from local taxation receipts (annual land value taxes preferably) and be distributed by the City/County Development Boards as part of a Participatory Budget. Community services may also be funded by way of a voucher scheme targeted at vulnerable and needy individual’s families as described above for arts, sports and culture. Section 3.5 Defence The naval service is essential to the preservation of our extremely valuable fisheries and shellfish commons, as well as the EU required protection of Marine SACs. Consideration should be given to diverting funding from other areas of defence to expanding and modernizing the fleet.

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Section 3.6 Education and Science Education is a human right that gives access to the knowledge commons of science and culture. Without addressing the detail of proposals for education cuts, the Environmental Pillar favours the simplification and empowering effect of demand-led funding of education rather than supply-led solutions. Children and adults should be given vouchers for education to be used in the school of their choice whether public, private or not-for-profit. Extra vouchers can be given for science education to support both pupils and teachers in this vital knowledge area. Top up vouchers can be given to targeted groups such as travellers, people with disability, new immigrants, newly unemployed, long term unemployed etc. School transport vouchers should be distributed on an equal per capita basis regardless of location. The scheme should be designed not to incentivise remote housing as proximity to school, so that children can walk and cycle, is the optimum solution for many proven health, social and economic reasons. Following such reforms externally-imposed rationalisation of the education sector may not be necessary. Section 3.7 Enterprise Trade and Employment Without addressing the detail of proposals for cuts in this area, the Environmental Pillar supports the simplification and empowering effect of universal support systems such as citizen dividends form commons assets, and vouchers to provide education and community services. Consolidation of existing agencies must be accompanied by greater transparency and accountability as required by the Aarhus Convention. A whistleblowers Charter must be part of the re-organisation outcome. Section 3.8 Environment, Heritage and Local Government Reduced capacity for environmental and ecological expertise The staff complement of the Environment Section of the DoEHLG is recommended for reduction by 25. It is not clear where these may take place but it important that the Biodiversity Unit is retained along with its support staff (1 person). There are existing and additional proposed incentives to reduce personnel which will exacerbate existing capacity difficulties within NPWS in particular. There is an ongoing NPWS Structural Review. We have already made a submission on this and essentially the capacity is inadequate, this is supported by the rulings of the European Court of Justice. The role of the NPWS is crucial in delivering Irelandâ&#x20AC;&#x2122;s commitments regarding the EU Habitats and Birds Directives, and in the wider monitoring and protection of the environment. The NPWS is already under-funded and struggling to fulfil its role and further reductions are therefore to be resisted. The capacity should be built upon, not

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reduced particularly given that he organisation has been starved of resources over a 30 year period, this has not been addressed. Given the increased emphasis in European directives for ecological or ecosystem approaches (for example the Marine Framework Strategy Directive, Water Framework Directive etc) and the impending ECJ fines (re the EU Habitats and Birds Directives), will also need for ecological expertise within other departments and competent authorities, via NPWS or provided in-house. Departmental responsibility changes While the transfer responsibility for inland fisheries to the Department of the Environment, Heritage & Local Government is a positive development, the proposed administrative efficiency that the D/AF&F would assume the cost of the National Parks & Wildlife Service’s Farm Plan Scheme is of significant concern. This scheme should be delivering biodiversity benefit – and should be retained within DoEHLG.. •

The role and positioning of Comhar The report proposese the merger of Comhar into the DoEHLG. NGOs have been lobbying to have this body under the Department of the Taoiseach as sustainability is a core principle to all Government functions. Comhar and its associated sub groups such as the Biodiversity Forum should remain extant in all other aspects.

Central management of research funding For all areas, research funding is proposed to be managed by a central body within DETE. This along with changes in procurement policy may have an impact on our method of acquiring funding and who the decision-makers are.. It should be ensured that funding for biodiversity, natural resource management and climate change research is not reduced or compromised.

Review of agencies (C4, D2) The report identifies the review the operations of Bord na Móna to achieve optimal value, a review of the Environmental Protection Agency (in 2009) including the rationalising of office locations, and administrative savings from An Bord Pleanála as well as the creation of administrative efficiencies in Heritage Council. These changes should only take place where it can be ensured that the delivery of biodiversity obligations are not compromised.

The Environment Fund (plastic bag tax receipts and landfill levies) represents the earth’s capacity to absorb waste which is a commons good. In line with our policy re commons elsewhere the use of the commons should be charged for and the receipts used to conserve the resource with the surplus returned as a dividend to the citizen beneficiaries. Contrary to the Report recommendations, the Environmental Pillar proposes that the Environment Fund remains hypothecated to support waste minimization, recycling processing environmental protection, sustainable development research etc and to support agencies and NGOs that contribute to that aim. A strong case could be made that

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Environmental Pillar Submission on the McCarthy Report

all waste charges should be treated the same way and not be returned to local authority general funds but hypothecated in the same way. The Environmental Pillar proposes that River Basin District Trusts hold, supervise and sell water resources in their catchment areas – the natural bioregions. Local authorities would pass these charges to consumers charging them in turn for water use over a basic quota. Detailed Paper 8. Para E2 (of Volume II) The Environmental Pillar does not support the removal of services from local authorities to national bodies, but rather welcomes the commitment for regional provision of some services under the “Renewed Programme for Government”. viz “We will start on a far reaching reform of local government in Ireland which will strengthen the strategic role and function of regional authorities in planning, transport, water and waste management.”9 Annual land value taxation would reward effective infrastructure investment by local authorities as the value of land adjacent to good infrastructure will rise and lead to increased LVT receipts and so on in a virtuous cycle. Whilst concurring with the urgent need for local government reform the Environmental Pillar submits that the proposal to create 22 unitary county authorities proposed in section 3.8 will not produce effective government capable of implementing nationally agreed spatial policy. •

there are currently 88 different planning authorities with boundaries that do not reflect modern functional units. This is ineffective and inefficient.

County Councils have consistently failed to represent the interests of communities in respect of decisions relating to land use, development and planning. The Ombudsman referred advisedly to ‘public cynicism’ and evidence in the Flood Tribunal pointed to anti-democratic intrigue and corruption which in no small part has led to the current collapse of the construction industry. Justice Quirke also referred to the abuse of the county council rezoning system in the High Court Case, Smith and McEvoy versus Meath County Council there has been an appropriate unwillingness to devolve power or money-raising powers to Councils due to these and other problems; however, this leads to a situation where power is concentrated nationally in the different Ministries and agencies. Reform of local structures is required before power to tax, spend and deliver services can be devolved. The Environmental Pillar proposes a system of local government based on 6 Regional or City Region authorities primarily responsible for land use and transport with the remit to grant outline planning permissions and zone land for development

9 Renewed Programme For Government page 36

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Environmental Pillar Submission on the McCarthy Report

where necessary. Full time paid members (approx 25 in each authority except Dublin which would have 60 members) would be drawn from County Councils and public community organisations. •

International and Irish research seems to suggest that the need to compete in the global economy requires the development of City Regions, and that these should have good universities and clusters of knowledge centres.

Current regional authorities may shortly be given greater power in the new Planning Act but at present these authorities are under-resourced, poorly staffed and mirror many of the problems of county councils and their democratic deficit. Without reform they will not be able to give the leadership demanded of them.

An Ombudsman should monitor the work of the new regional authorities in line with national government policy 22 - 26 Counties would remain (incorporating City and Town Councils) with revised boundaries to reflect functional urban areas) as service providers to implement regional policy. They should be bound by law as laid out in the new Planning Act shortly to be debated. Council members would be unpaid. The people clearly have an affinity for county, town and parish councils that may not be transferred to regional authorities. This social capital should be protected but in a way that cannot be perverted. As proposed by McCarthy, Town Councils would lose their existing inconsistent powers but Town and Parish Councils should remain with a new remit as a debating and consultative council of unpaid elected members.

As localisation becomes more vital this level of governance will become increasingly relevant and will need to become more central to people’s lives throughout the country, not just in a few municipal towns as present. However, at this level there will be increasing community engagement less dependent on a money economy. Financial reward for community leaders on local councils will not be the motivating factor though key members may move onto County and thence Regional Authorities where the additional commitment will be supported by adequate pay. The shift of resources from county to regional level should result in financial savings. Further savings could be found by de-zoning land no longer required for development outside of primary growth centres . This will remove the duty of local authorities to service this land and thus reduce expenditure on the wider dispersal of physical and social infrastructure.

Section 3.10 Department of Foreign Affairs Increase in Overseas Development Aid (ODA) The Report recommends further cuts in ODA and an extension of the timescale for reaching the UN target of 0.7% of GNP. This must be resisted as Developing Countries will need financial support from Developed Nations to help them deal effectively with the emerging calamities due to GHG emissions and climate change. As part of the global Page 18 of 21


Environmental Pillar Submission on the McCarthy Report

moves to prevent climate change Ireland must keeps it aid promise to the worlds poorest and help them deal with catastrophes not of their own making. This will require that an even higher target to be delivered on. Education for Sustainable Development In this context there is a need for more funding, both in Ireland and in the developing world, for education programmes and projects aimed at increasing greater awareness resulting in more concrete actions to halt Climate Change and return society to a more â&#x20AC;&#x2DC;sustainableâ&#x20AC;&#x2122; development model. Section 3.17 Department of the Transport The Pillar would like to highlight the great lack of any analysis, let alone Strategic Environmental Assessment, of the Transport Programmes. It is recognised that the Report only makes recommendation on current expenditure and does not address capital expenditure. In the transport portfolio this creates particular problems which will lead to poor decision-making unless addressed. Many of the rail and roads projects are being funded over a considerable period of time by PPP. Therefore, a project might appear to have a low capital cost but will require high, but unrevealed, current expenditure to pay for the PPP over a long timeframe. Because the data has been withheld a comparative assessment of light rail and bus, or inter-urban motorway versus rail, is impossible. In refusing to give out information, Government and Government agencies hide behind the cloak of commercial confidentiality. In short, it is impossible to properly assess expenditure in the Department of Transport without a breakdown of the different PPP projects and their real expected current and capital costs. Therefore, the concentration of the report on current expenditure is misplaced. The judgements contained in the report are therefore flawed, leading to a situation whereby the bus services which provide accessibility, and are proven to reduce fuel use and carbon emissions are being cut while prestige road and LRT projects â&#x20AC;&#x201C; which tend to increase aggregate emissions - are being continued as PPP projects. The above paragraph also explains why the public transport current budget is earmarked for a 20 per cent cut whereas the roads budget would only see a 14 per cent drop. Again, this proposal is wholly inconsistent with the Renewed Programme for Government 2009 which is committed to prioritising public transport. Sale of Bus Eireann Expressway: It is premature to suggest the sale of the Bus Eireann Expressway network until a plan has been developed to deliver on the commitment in Smarter Travel to deliver a seven day a week bus service to all rural villages.

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Environmental Pillar Submission on the McCarthy Report

In effect, remunerative services within Bus Eireann cross-subsidise transport to villages, and so the sale of the former would result in greater need for money for the latter. Disposal of land/property holdings: Given the excessive cost of compulsory purchase of land for recent road and public transport projects land holdings should not be disposed of without a detailed review of future requirements to meet the Smarter Travel actions. It is also premature until the general supply of development land is reformed. Road Pricing: Not all road pricing proposals deliver environmental benefits. Systems which are specifically tailored to address congested roads rather than use can just encourage the displacement of traffic rather than its reduction and thereby contribute to further sprawl and eventually further traffic. From an environmental perspective a tax on carbon is a more efficient measure from both an environmental and economic perspective. Equity issues need to be considered with both a carbon tax and road pricing. Proposed Discontinuation of the Green Schools Initiative and the Rural Transport Programme: The report says that if a Department cannot do something economically they should look to get someone in to do it for them. Green Schools and the Rural Transport Programme do just this. They mobilise community and voluntary resources to efficiently deliver services. Furthermore the Rural Transport Programme serves people who would otherwise have no access to transport. This realises savings for other Departments such as the Department of Health. The report cites high levels of car ownership as a reason for cutting Rural Transport services to the disabled or elderly, is perverse. Similarly the objection to the Green Schools Initiative seems to be less the cost of it and more that it is to “convince school children and their parents to walk to and from school rather than drive”. Green Schools is in fact the most cost-effective way to create a modal shift in transport among school children, with the studies pointing to a 10 – 15 per cent shift away from cars and towards cycling and walking. It is unfortunate that the authors of the report did not have an opportunity to access the relevant literature on the topic; had they done so the outcome would have been to recommend extending the Green Schools programme, as delivered in the Renewed Programme for Government. One example of value benefits missed by the report’s authors lies in the health area – the reduced life-long obesity, reduced life-long health costs, and higher productivity, owing to reduced childhood obesity. Removal of the PSO Subsidy for Regional Air Services: The Environmental Pillar agrees with removing funding for the Public Service Obligation, which is promoting the use of unsustainable transport in direct competition with more Page 20 of 21


Environmental Pillar Submission on the McCarthy Report

sustainable systems, whilst encouraging the spending of scarce public resources on the development of unsustainable airports. In this context the proposal to close rail lines that are lightly used should be resisted. The country is only now counting the costs of such short sighted actions in the past. Rail Line Cuts: It makes no sense while the Western Rail Corridor is being built to enable services between Limerick and Galway that the rail link between Rosslare to Limerick should be removed. It is not extravagant to connect Irelandâ&#x20AC;&#x2122;s principal cities with a modern rail system and it is important for the countryâ&#x20AC;&#x2122;s competitiveness to have high quality infrastructure. The Ballina line is critically important for national rail freight, and has seen significant increases in container traffic throughout 2008 and 2009: the writers of the report appear unaware of this. Similarly, the Ballybrophy line has also seen increased patronage in terms of passenger traffic. It is poised for significant growth with the opening of the Cloughjordan eco-village conference centre with an increased number of events in 2010. Merging of QUANGOs: The creation of a single safety body and the merging of the RPA and NRA might lead to more integrated planning and delivery of services.

Contact information: For further details please contact Michael Ewing, Social Partnership Coordinator. Postal Address: Environmental Pillar of Social Partnership. Tullyval, Knockvicar, Boyle, Co Roscommon Telephone: 071 9667373 Mobile: 00353 (0)86 8672153 Email: michael@environmentalpillar.ie Skype: michaelk.ewing

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Submission on the McCarthy Report  

McCarthy report

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