1. The previous submission from Sustainable Skerries highlighted that continued economic growth is, in fact, unsustainable. While the latest draft talks about sustainable growth, green and circular economy, the development plan is still presented as one which prioritises economic growth above all else. There is a language of extensive economic growth through this Chapter 7 in particular and we recommend that any further revisions reflect deeply on the true compatibility of extensive economic growth and truly sustainable development in Fingal.
2. The majority of references to tourism are leveraging Fingal's proximity to the airport and therefore focus solely on international tourism and air travel. Aviation is by far the most energy-intensive and high carbon form of travel. Furthermore, an unjust distribution of the global carbon budget is used through air travel whereby only about 11% of the global population travel by air (only 2-4% of global population fly internationally) and 1% of the world population emit 50% of CO2 from commercial aviation (Gossling and Humpe, 2020). We recommend the promotion of and a reemphasis towards domestic tourism and alternative modes of travel by making Fingal easily accessible from all parts of Ireland (and the world by including Ferry ports for international tourists) via public transport and greenways.
3. The plan aims to create "high quality employment that is well paid and sustainable" (p. 244) yet puts this primarily in the context of office work in industrial parks with minimal mention of employment which serves the community (which are dealt with at length in other chapters) - food growth, food sales and distribution, childcare, elderly care, healthcare, education and other public services. The plan also frequently refers to the high level of education in the area in terms of University degrees yet does not address the relevant skills required by the population to meet targets for building and retrofitting homes in the area for the coming years to meet climate targets. This chapter of the plan emphasises "highly skilled workers" throughout with the aim of developing this aspect of employment in Fingal in areas such as ICT, pharma and financial services with very little attention given to how sustainable employment in public services (and the required skills) can keep up with demand for truly sustainable development. We recommend that any plans for employment in Fingal address first and foremost the jobs (and the development of skills for such jobs) that are most needed to support Fingal and Ireland in meeting its climate targets (e.g. retrofitting homes, repair services to promote the circular economy bill) and creating local and national food and energy security. In addition, we would like to see more emphasis on employment to alleviate pressure associated with growing populations on existing public services such as childcare, care for elderly, healthcare, and emergency services.
- The section with regard to the rural economy encapsulates the green and circular economy to a much greater extent than plans for areas with higher population. There is a stark contrast between the plans for the highly populated areas of Swords, Balbriggan and Blanchardstown and lower population areas. Objectives for the "rural economy" are presented in a way which repurposes and regenerates what exists while building on local skills whereas plans for unsustainable extensive growth in areas such as Swords and Blanchardstown will results in poor use of land and extremely carbon intensive building activity and alteration of the physical environment while also increasing congestion in the areas and impacting wildlife.
Policy EEP23 states that the council will provide “Support and protect existing rural economies such as valuable agricultural lands to ensure sustainable food supply, to protect the value and character of open countryside and to support the diversification of rural economies to create additional jobs and maximise opportunities in emerging sectors, such as agri-business, renewable energy, tourism and forestry”. In line with the recommendations made in earlier points, we recommend that the objectives for the rural economy in the FDP, including sustainable agriculture and horticulture, renewable energy, tourism and forestry, are not confined to rural areas and extend beyond areas with populations of less than 10,000.
- It is very positive to see the inclusion of a section on circular economy within this chapter. However all other sections within the chapter are presented in contrast to the premise of the circular economy and appear to emphasise growth and expansion of new industry and products above all else without consideration for how circular should be embedded into the model of any business operating (particularly manufacturing) in Fingal going forward. We would like to see some explicit examples of how existing and new businesses in Fingal will be incentivised to invest in circular products or services in order to bridge the current circularity gap. For example the plan should emphasise how Fingal will help businesses transition to business models that build on the interaction between product and service such as circular supply models, resource recovery models, product life extension models, sharing models and product service system models. The transition away from fossil fuels and energy efficiency measures can only address 55% of our emissions. The remaining 45% comes from making things.
- The FDP aims to “promote sustainable growth opportunities” in the marine sector in towns such as Howth, Balbriggan, Skerries, Malahide and Donabate (p.261). However it is important for the plan to note that overfishing across Irish waters has already driven the collapse of many stocks and therefore threatens fisheries with closure if quotas are not reduced in line with scientific evidence. For example, the population of cod in the Celtic Sea has been reduced by 88% since 1981 (www.birdwatchireland.ie ).
- In Objective EEO35 – ICT, Financial and Banking Sector the plan aims to “Promote the growth of the ICT and financial and banking sector in Fingal by facilitating the conditions conducive to such development including the creation of high quality physical environments offering a range of building and office accommodation types, supported through the provision of the necessary services and public transport infrastructure”. We would welcome more elaboration on how "high quality physical environments" for such industry are characterised and what measures would be taken to ensure they do not result in the creation of low quality natural environments.
- The plan proposes to expand the equine industry in Fingal without any clear rationale or consideration for the ethical and environmental implications of such growth. Animal rescue services in North Dublin have already pleaded for increased supports for their work with horses:https://www.dspca.ie/dspca-and-the-equine-problems-in-dublin We recommend that plans to grow the equine industry are removed from the FDP, and instead the council will engage with animal rescue services to learn more about how they can collaboratively promote animal welfare in Fingal, reducing demand on their services.
- Policy EEP29 – Regenerative Farming & Community Supported Agriculture states that “Support and encourage Organic and Regenerative Farming and Community Supported Agriculture in the Fingal Area”. This however is the only mention of this agricultural method throughout the plan and no follow-up details are provided as to how this would be supported and encouraged. Such details as to how organic and regenerative farming and community supported agriculture would be supported and encouraged, both for new farmers and farmers wishing to move to organic / regenerative, is required here.