5 Pery Square,
Limerick,
V94 EV1F
Ireland
Ph: +353 61 953100
Web: www.antarisconsulting.com
5/2/24
Subject: Limerick Local Authority Climate Action Plan
I am writing to you on behalf of Antaris Consulting, a sustainability consultancy firm based in Limerick. Our firm is dedicated to acting on the imperative of sustainability one work day at a time. As a company operating for 30 years is Limerick city we have a shared interest in seeing our city and region thrive by successfully decarbonising and addressing our sustainability challenges. We work with organisations large and small tackling the climate challenge. In the spirit of partnership and friendly collaboration we would like to offer the following advice gleaned from working across a variety of organisations on climate and sustainability issues.
We understand the scale and magnitude of the task required which goes well beyond the easy wins and low hanging fruit. We recognise and congratulate the Council on the work that has gone into the plan to date. We do however, based on our professional experience, have concerns that the action plan in its current form is insufficient to realise the GHG reductions required to meet the 2030 target or put LCCC on a trajectory to a net zero future by 2050.
Please find a list of recommendation for your consideration. Antaris consider that implementing these measures will result in an action plan which is more fit for purpose.
1. Take on board the lessons learnt from attempted implementation of previous climate actions
Antaris have a strong background in management systems and have successfully implemented the Plan Do Check Act and its iterative focus on continuous improvement by learning from past performance. Limerick City and County Council (LCCC) have a history of climate action that they can develop learnings from to improve this latest iteration. In 2016 LCCC signed up to the Covenant of Mayors and produced a Sustainable Energy and Climate Action Plan. In 2019 LCCC signed up to the Local Authority Climate Action Charter which required the council to, inter alia, climate proof plans and projects and report annually. In both cases LCCC failed to submit the required reporting of progress. A review of the reasons for this is likely to identify challenges that act as barriers to successful implementation of the Climate Action Plan. Antaris suggest that identifying these barriers and finding ways to mitigate them is key to a successful action plan implementation.
2. Ensure there is appropriate specificity for actions
In many cases the actions listed are too vague to be meaningful. It is not clear who exactly is to do what by when. An example is action B10 “implement the LSMATS Strategy”. This strategy is for a period to 2040, 10 years after the 2030 deadline for halving emissions. In addition, the strategy modelling shows that it will not achieve the required emissions reduction as the NTA have explained “The NTA undertook comprehensive modelling assessments of the LSMATS throughout 2021 and 2022 as it related to [transport] emissions. This work demonstrated clearly that significant measures outside the remit of the NTA and the LSMATS would be required to be implemented in order to reach the 50% target.”
3. Focus on outcomes as well as inputs
Many of the actions in the climate action plan have no target, and the tracking measures relate to the inputs (e.g. study completed, no. of actions implemented or annual reporting). What we care about is outcomes in terms of emission reductions. Carbon reductions is only mentioned as an indicator for one action (B10 -implementation of LSMATS), but without any target listed, nor timeline, nor method of calculating it, nor any of the individual actions that would lead to a reduction in carbon emissions. Antaris recommend including an expected amount of carbon emission reductions alongside each action. Antaris note that the 2016 Sustainable Energy and Climate Action Plan submitted as part of the Covenant of Mayors had GHG reductions listed alongside each action.
4. Ensure appropriate governance
Action G3 requires a monthly progress update on the implementation of LACAP as a standing item on the monthly agenda for the Management Team. It is not clear to Antaris how this can work in practice without specified targets or timelines. Actions G15 (establish a monitoring and reporting system), and action G7 (establish KPIs) will help but again these are only scheduled to be tracked at the annual report. Antaris suggest that without an amount of GHG reduction for each action it will not be possible to track or prioritise actions.
Antaris note that the Guidance for preparing the LACAP requires that they …must demonstrate alignment with the key principles of these guidelines to ensure that the local authority climate action plan is: Ambitious, Action-focused, Evidence-based, Participative and Transparent.” and …In the case that the undertaking has not set measurable time-bound outcome-oriented targets, whether and how it nevertheless tracks the effectiveness of its actions.
Antaris do not consider that LCCC has successfully achieved these requirements in this current draft of the plan.
5. Undertake a risk analysis
Antaris recommend that the Council assess the risks associated with the Climate Action Plan’s implementation so that the risks can be tracked and mitigated. Risks might include a lack of political support, a lack of funding, or a lack of internal expertise.
6. Ensure plan is aligned with national climate action plan
Antaris note that there are several actions from the 2023 Climate action plan relevant to the LCCC’s work which have not been addressed in the LACAP. These include:
- TR/23/4*(TF) including specific actions and indicators in respect of accessibility, modal shift and active travel.
- TR/23/14*(TF) consistent implementation of DMURS.
- TR/23/25*(TF) identifying roads and streets suitable for road space reallocation.
- TR/23/27(TF) Pedestrian enhancement plans.
- TR/23/32*(TF) Leverage of Protection and Renewal road infrastructure programme to enhance safety of sustainable mobility users.
Antaris recommend that the LACAP is reviewed to ensure all relevant actions in the National action plan is reflected in the LACAP, and that it is revised annually to incorporate the latest updated national plan.
Thank you for your consideration of these points and we are happy to discuss this further if that would be useful.
Your sincerely,
Gerry Higgins
CEO
Antaris Consulting
