Submission on the Development of a new Solid Fuel Regulation for Ireland, April 2021

Community Law & Mediation recognises the urgent need for comprehensive national regulation of solid fuel burning, which extends to regulation of specified solid fuels across the entire state and increases the range of fuels to be regulated. The compelling underlying rationale for such extended regulation is public health and emissions considerations. However, it is imperative that any new regulatory regime be implemented in line with principles of just transition and that the consultation and implementation be informed and responsive to the needs of individuals and communities likely to be disproportionately impacted. We believe that regulation must be implemented without undue delay and that it must be accompanied by properly resourced and accessible redistributive measures to limit the impact on communities experiencing deprivation, including, for example, energy poverty.

In our recent submission to the Department of the Environment, Climate and Communications on the Development of a new Solid Fuel Regulation for Ireland, we made the following recommendations:

  • Design and implementation of a human rights and equality matrix to be part of the consultation process on climate adaptation policies, to ensure full public engagement and participation on environmental matters
  • A nationwide ban on specified solid fuels, including bitumous coal, peat and wet wood
  • Consolidation of air pollution legislation, to include consolidation of the regulations implementing the Air Pollution Act 1987 and publication of accompanying guidelines that set out the obligations in plain language
  • Updating of air pollution legislation to include incorporation of WHO guidelines in respect of PM 2.5 and PM 10 standards
  • Collation of accurate and up to date data on energy poverty and other socio-economic disadvantage as linked to reliance solid fuels
  • Design and implementation of properly resourced and accessible redistributive measures to alleviate the negative and potentially disproportionate impact of solid fuel regulation on vulnerable groups, in line with principles of just transition

Click here to read the submission in full