I refer to the draft Transport Strategy for the Greater Dublin Area 2016 to 2035 which has been sent to your office by the National Transport Authority​.The purpose of my letter is to draw your attention to the obligations which now apply to you and all other relevant bodies under section 15 of the Climate Action and Low Carbon Development Act 2015 and ​to highlight ​the relevance ​of these obligations ​to the adoption of a Transport Strategy.

The draft Transport Strategy which has been submitted to you envisages a significant increase in greenhouse gas emissions from transport in the Dublin area during more than half of the time period specified in the Act for transition to a low carbon, climate resilient and environmentally sustainable economy. As documented in the accompanying documentation, the strategy would lead to a minimal reduction compared to a ‘business as usual’ scenario.

The reason the Strategy has this minimal effect is that, as confirmed to me by the National Transport Authority (NTA), greenhouse gas emissions abatement was not one of the objectives which drove the development of the Strategy.

I pointed out in my submission to the NTA in response to their public consultation ​on the draft Strategy that, on the enactment of the Climate Action and Low Carbon Development Act 2015, adoption of the strategy as drafted would be illegal due to its failure to comply with the obligations in​ s.15 of the Act. From my reading of the subsequent draft submitted to you, my observation seems not to have been taken account of.  I attach a copy of that submission for your information.

Manifestly, it would not be lawful for you to approve the draft Strategy without fundamental alterations aimed at bringing transport in Dublin in line with transition to a low carbon climate resilient and environmentally sustainable economy.

Cllr. David Healy