Environmental Study Group at the SAI

Sociology Association of Ireland (SAI) Environment & Society Study Group – Submission to the Climate Action Plan 2024 Public Consultation

To The Department of Environment, Climate and Communications,

In the following consultation submission, you will find our recommendations and comments on various aspects of the proposed Climate Action Plan 2024, broken down by chapter and, in some cases, by specific section. We thank you in advance for reading our consultation submission and considering our recommendations and broader comments on CAP 2024.

C4: Research and Innovation

Social and Behavioural Research (

As the only dedicated environmental sociology group within the Sociology Association of Ireland, we would welcome lending our expertise to the Advisory Group on Social and Behavioural Sciences.

We have several disciplinary points regarding the contribution environmental sociology could make to current and future climate policy actions that we believe should be considered in policy design research that emerges from CAP 2024. A focus on “attitudes, perceptions and behaviours” can be dangerously misleading, especially when failing to account for the complex societal dimensions in which all humans are immersed. Treating individuals as merely requiring certain attitudes and perceptions to arrive at certain behaviours will lead to overly parsimonious and linear descriptions and prescriptions which individualize responsibility (Shove, 2010, 2011). The omission of society from such models renders many such approaches unworkable in context and is arguably a key reason behind the ‘replication crisis’ haunting psychological research (Open Science Collaboration, 2015; Van Bavel et al., 2016). A more sociological approach is necessary to offer a more holistic and systemic understanding that is focused on more societal features such as institutions, culture, class, gender, ethnicity, government and economy, field of occupation, etc. – all critical factors for enabling a ‘just’ transition to a lower-carbon Ireland.

In addition, a social gap between stated attitudes and actual behaviour has often been observed in studies examining barriers to the implementation of renewable energy such as wind capacity expansion (Bell, et al. 2005). Therefore relying on attitudinal and behavioural research without considering the wider, complex societal features is unlikely to result in a successful transition to a more sustainable society, which requires ‘a buy-in’ from all key stakeholders (Lorenzoni and Pidgeon, 2006). The ‘nudging’ approach, favoured in behavioural studies, can also lead to limited success without further considerations of sociological perspectives. A study by Ruokamo, et al. (2022) found that ‘nudging’ helped to reduce electricity consumption within households who are already more involved in following their electricity consumption. Reliance on ‘nudges’ can therefore lead to misleading policy interventions which fail to target key target groups.

A particular sociological approach to emerge in recent years is known as “Practice Theory” (Shove, Pantzar and Watson, 2012). Currently, its primary advocate is Prof., Elizabeth Shove whose writings on practice theory have been cited over 35,000 times (a very high figure in the social sciences). It advocates replacing research into individuals and their ‘behaviours’ with a focus on ‘practices’. Behaviours are deemed too individualising and voluntaristic to present an accurate reflection of how what people do is in part determined by the structure of everyday life. ‘Practices’ on the other hand – such as cycling, car-driving, flying, etc – have a social, cultural and material (e.g., equipment, infrastructures) presence that stretches beyond the individual to across society as well as deep into history.

Such a perspective helps to recognise that the emergence of car-centric cities throughout Europe was not a simple evolutionary replacement of one technology – the bicycle – with more advanced technology, but was instead heavily political and class-driven and initially resisted by many workers who depended on the bicycle (Oosterhuis, 2016).

It also points to socio-cultural aspects. For example, how cycling is mainly casual in mainland Europe but often fitness-related in the UK and Ireland, which in turn clashes with particular gendered clothing restrictions and ideas of modesty thereby contributing to limiting take up by female school pupils whose uniforms require skirts (Egan and Hackett, 2022).

How practices are bound up with other practices is also a crucial component of practice theory and essential to understanding the possibilities or requirements of social change. Mattioli et al’s (2016) data mining of time series diaries on the time-use of the car illustrates this. Through its cargo function, the car is heavily bound up with a multitude of other practices. Drivers ferried children to school, the dog to a place to walk it, waste to waste disposal areas, and in particular shopping etc. Any shift to supplant the car with public transport, walking, or cycling needs to factor in this cargo function as well as how to become integrated into similar practices which in effect is a means of integrating these lower-emitting modes into everyday life. Everyday life, according to practice theory, is constituted out of a multitude of interconnected practices.

Practice theory also has offered effective insight into the occurrence of “performance gaps” (van Dronkelaar et al., 2016) in energy-saving technologies – the changeable nature of ‘comfort’ for example, which has led to a failure to realise energy savings from heat pumps as some UK families instead increase comfort levels (Gram-Hanssen et al., 2017).

As national experts in practice theory and broader environmental sociological approaches, we can offer a fresh perspective on the policy solutions required to tackle the stubborn problems of behaviour change that the current emphasis on ‘nudge’ tactics may overlook.

C11: Carbon Pricing and Cross-Cutting Policies

Digital Transformation (11.2.4)

The COVID pandemic accelerated the transformation of work, in particular creating opportunities for remote and hybrid working. While such ways of working have potentially some significant personal, community, and social advantages, in terms of consumption and the impacts on the environment little is known about the long-term consequences of this method of working. In particular, issues such as reductions of office space in urban centres and the resulting ‘hollowing out’ of towns and city centres and the transfer of energy and overall patterns of consumption from businesses and organisations to the individual worker are issues and concerns that require urgent policy attention and longitudinal empirical research. The potential rebound effects of remote working on residential and daily mobility in terms of possible increases in the frequency or distance of journeys, such as an increase in non‐work‐related travel on remote working days, as well as effects such as residential relocation or multilocal dwelling (Hostettler Macias et al., 2023) are also issues of some concern. Moreover, the long-term sustainability of remote and hybrid working is fundamentally dependent on stronger worker protection than currently exists for such workers, in particular: the extension of all working conditions and rights that exist for those working at a central location to those who choose to work from home, remotely, or in a hybrid way. Such protections require explicit reference to remote working in current policy and regulation.

C15: Transport

Communications and Engagement Work Programme (

In relation to both Public and Local Authority Communications & Engagement Workstreams, research from our group can improve and refine communications and representations that can support modal shift and broader road space reallocation/car traffic demand management measures. In particular, deriving from study of public opposition to a major active travel infrastructure project in Dún Laoghaire-Rathdown (the ‘Active School Travel’ scheme) (Egan and Caulfield, 2024a, 2024b, 2024b), following analysis of a sample of public consultation submissions, it was found that two interrelated narratives (or discourses) underpin a significant extent of public opposition to active travel measures that involve redistribution of rights to space, speed, and/or access from car traffic to foot/wheel and cycle traffic to reduce driving and promote modal shift (Egan and Caulfield, 2023, 2024a, 2024b, 2024c). In this research, a car-centric narrative of transport planning (Egan and Caulfield, 2024a, 2024b) and everyday mobility (Egan and Caulfield, 2024c) were identified as the major discourses of opposition. The summary report of Egan and Caulfield (2023) provides a concise account of the features of these discourses, and the recommendations for constructing new public and official (e.g., Local and National Authority) narratives that can be promoted and incorporated in pro-active travel behaviour change and planning proposal/implementation efforts. The recommendations within this report are presented below:

i. Cycle Mobility as Traffic: Wording cycle mobility/cycling/cyclists as “cycle traffic”. Through wording cycle mobility as “cycle traffic” in future proposals and public communications, cycling and cyclists can be legitimised as a form of traffic as opposed to something ‘in the way’ of traffic. Likewise, by using standardised wording of cycle mobility as “cycle traffic”, cycle spaces could be set up as elements of a traffic/transport system rather than spaces that necessarily reduce or disrupt a traffic/transport system. Lastly, avoiding the use of ‘traffic’ as a general term and instead systematically using “cycle/car/motor/pedestrian/mixed traffic” can help to more transparently present any claims regarding ‘traffic’ in relation to the mode in question.

 ii. Traffic as a Malleable Substance – A Metaphor of Conversion: Within the technical discourse of transport planning identified, the possibility of modal shift as well as reduced mobility practices (i.e., ‘Avoid’ CAP targets) is absent. This absence of possibility is incorporated into the metaphorical rendering of traffic as an ‘immutable substance’ – something that is permanent rather than malleable. On the basis that modal shift can be stimulated through active travel measures, a counter-metaphor of ‘traffic conversion’ could be incorporated into an alternative transport planning discourse to contest working assumptions within the car-centric technical discourse of transport planning that car-based mobility (‘traffic’) is an immutable substance that must be diverted elsewhere with redistributive active travel measures.

iii. Car-Centric Planning as a Cause of Danger and Emissions: It is well established that car-based automobility has contributed to mass road traffic violence and unsustainable transport sector emissions brought about in part by the disintegrated practice of spatial planning and public transport planning (OECD, 2022). One possibility for addressing the construction of active travel measures as a primary cause of local danger and emissions may be measuring, quantifying, and publicly communicating the system-level (and local) effects that car-centric planning may have on the safety of people cycling and walking, as well as local air pollution.

iv. Vision-Led Planning: Based on the recent Greater Dublin Area Transport Strategy, official planning practice is moving towards a ‘decide and provide’ approach where planning decisions are made based on what is desired – such as increased cycling and walking and less driving – rather than what is forecast (National Transport Authority, 2021). In light of the evidence that an underlying principle of demand-led planning acts as a major normative basis for redistributive active travel planning opposition in Dún Laoghaire-Rathdown, explicit representations of a more ‘vision-led’ approach that does not necessitate the reproduction of the current mobility regime (Lyons & Davidson, 2016), along with clear explanations of why such an approach is needed as an alternative to ‘predict and provide’ would be beneficial.

v. Driving as Unsustainable: While the discourse of everyday mobility identified in Egan and Caulfield (2023, 2024c) construes driving as the essential mobility practice for everyday life, a discourse that decentres the car as the basic mode might emphasise the car as fundamentally unsustainable as the primary form of everyday mobility in urban contexts – particularly in relation to population growth and policy aims for more compact urban development in Ireland (Department of Public Expenditure and Reform, 2021). This would shift emphasis away from driving as essential toward adapting the transport system to enable alternative forms of everyday mobility as essential, including through demand management measures. On these grounds, sustainability could be argued in relation to sustaining everyday life and the personal and group mobility this may involve, rather than arguing based on ecological sustainability.

vi. Driving as Conditional: As a counter-representation to a construal of cycling as conditional, the dependencies that are incorporated into (and often met) in the practice of driving can be represented in an everyday mobility discourse that decentres the car. This could involve, among other things, a representation of how driving as a practice is extensively dependent on a vast technical system (OECD, 2022; Urry, 2004). This might include depictions of how driving is dependent on the provision of extensive spatial provision for driving and car parking, major state roads investment and maintenance, driver licencing, car insurance, car ownership, road traffic policing, road safety campaigning, access to affordable fuel, and the widespread availability of fuelling stations. Proposal and policy images of driving could also reflect what peak car traffic looks like in urban and suburban locations, which can often be congested.

vii. Cycling as Practical: Cycling can be used to complete a variety of everyday tasks (Ministry of Infrastructure and Water Management, 2020) under a variety of conditions (Hudde, 2023). It is proposed that a counter-construal to cycling as conditional could be the representation (including through imagery) of cycling as an all-purpose, all-weather, all-day activity. Focusing on cycling as practical for all purposes, this could involve the inclusion of images of people cycle-shopping and cycling-chauffeuring (e.g., as a group or with a cargo bike for utilitarian journeys). Portraying cycling as an all-weather and all-day mode, on the other hand, could involve the inclusion of representations of cycling in the rain, in overcast conditions, and cycling at night. All of these representations could challenge the construal of cycling as a mobility practice that is fundamentally limited to a small variety of journeys (e.g., individual commute journeys) within a restrictive set of conditions (e.g., warm, dry and bright weather).

Enhanced Spatial and Land Use Planning (

Integrating transport, health, and environmental objectives into urban and rural spatial planning and land use policies is made more possible by improving collaboration, coordination, and cooperation between all levels of the relevant authorities and the communities directly impacted. Several issues require more attention in policy design and implementation. The location of work opportunities close to existing and new residential builds and communities – a key commitment under the Project Ireland 2040 (2024): National Planning Framework – must be prioritised. A ’15 min city’ concept, which requires a redesign and replanning of urban spaces so that residents can access all of their basic essentials at distances that would not take them more than 15 min by foot or by bicycle, (Moreno, et al., 2021), has been trialled in cities such as Paris. Residents can enjoy a higher quality of life and sustain a decent urban life as they can access all required social functions (e.g. living, working, commerce, healthcare, education and entertainment) within a 15-minute radius. A redesign of urban areas in Ireland, which would avoid the use of cars to travel long distances to access social functions and would prioritise walking, cycling and use of public transport in accessing these could be achieved with holistic and inclusive planning. Equally, the redevelopment and regeneration of rural Ireland by promoting environmentally sustainable growth patterns is also needed. Transport and spatial planning and land use are inextricably linked and, thus, must be considered in unison and developed and implemented through a single body or agency in Ireland. There must be a focus on developing better nationwide public transport systems that are safe, clean, convenient, accessible, efficient and affordable for all citizens. Developing infrastructure, road signage and signalling to ensure safe healthy active and sustainable mobility such as walking and cycling must be a major priority in terms of future planning. Mobility management schemes for commuting to and from work, school, leisure travel and other such needs are required for each local region and county. Increasing the country’s annual afforestation rates, promoting forest management initiatives to increase carbon sinks and stores, improving grasslands, and protecting and rehabilitation of peatlands are all important ways in which the country can meet our obligations under the Climate Action Plan (Gov.ie, 2024).

Strategic Transport Planning ( – Galway

For Galway to tackle its periodic chronic traffic congestion, the use of private cars must be significantly curtailed and discouraged within and across the city. Galway is a medieval city whose core was never designed for the volumes of traffic it now experiences on an almost daily basis. Yet, many of the distances that daily commuters, who live in the city, need to travel are the shortest in the state (CSO, 2023) and do not necessitate the use of a private car. In curtailing private car use in the city, active and sustainable transport options such as walking, cycling, and public transport must be effectively supported in terms of space allocation, finance, and public and national representative leadership. Walking is perhaps the simplest mode of transport but, in the case of Galway, is critically neglected. The pedestrian routes between many of the main amenities and facilities in the city are characterised by neglect with poorly maintained and unkempt footpaths, obstructive street signage, the commercial colonisation of street space, illegal and inconsiderate parking, and inappropriate or non-existent road crossing. Cycling is equally marginalised with no separated and safe cycling lanes or throughways and no linked routes throughout the city. CycleConnects (NTA, 2022) routes in and around the city must be prioritised as a matter of urgency, and a similar level of planning is required for pedestrian walkways. In terms of public transport, a central element for improving sustainable mobility in Galway is the development and implementation of a light rail system. Given the topology of the city, a single light rail line running from 8km from Barna to Oranmore would cater for nearly 70% of the population of the city (Mc Gettrick, 2020). In addition to a light rail system, additional road space must be allocated to bus lanes that connect all residential areas of the city to the main facilities and amenities such as schools, universities, hospitals, places of worship, shopping centres, and major sporting venues. All of the nodes or pick-up points on the public transport network must be connected to residential areas through safe cycleways and walkways.

Strategic Transport Planning ( – Waterford

The move to a more cycling-friendly city would tie in well with Waterford’s recent PR successes as the ‘best place to live in Ireland’. The sustainability bridge is an important infrastructural development as it expands active travel possibilities – especially in cycling – to a large part of the city (i.e., Ferrybank). Prior to this cycling from this area was only for a few ‘urban warriors’ or on footpaths. However, the digital rendering of the bridge only shows a handful of cyclists and a few walkers and lacks ambition. The images are far from the images of Europe’s cycling cities where cycling is ‘traffic’ as opposed to here where it appears as a minor and brief spell of luxury for a few. Future representations of cycling would therefore benefit from recognition of cycling as a serious form of city travel and as ‘traffic’ in its own right. Connecting the bridge development to the rest of the city is also essential. This could be aided by safer parking spaces for bikes throughout and; the integration of cycling with local public transport via bike-carrying facilities as seen in European cycling cities. Working-class areas also need to be included in cycling infrastructure such as Ballybricken, which currently has been excluded from the rollout of regional bike-sharing schemes (i.e., action number TR/24/18). However, infrastructural developments alone will not be enough (as in Stevenage and Milton Keyes). On top of ‘demand management strategy’, which potentially over-emphasises an individualising consumer approach, stronger and more inclusive cultural and social connections need to be made between cycling and Waterford’s community groups, schools, technological university campuses, cycling campaigners, residents associations, Greenway enterprises, bicycle suppliers, and with Waterford festival and cultural activities as well as tying into a social history of cycling in Waterford. In order to understand more about how this could be achieved funding should be provided for local research – potentially with action research initiatives – and for environmental forums that serve to identify and make the most of local institutional and social capital.

Major Public Transport Infrastructure Programme (

We welcome that active travel access and cycle parking for passengers has been explicitly mentioned in plans for PT infrastructure development, and for considering new or improved active travel infrastructure provision. This will help to increase the catchment of public transport passengers independent of car use. Providing for cycling as an access mode for rail journeys is a particularly effective means of promoting cycle-public transport integrated journeys (Egan et al., 2023, p.5, ‘Integration’ as a public cycle planning principle). Importantly, it is likely that a considerable proportion of cycle access journeys to rail would involve long-term cycle parking (e.g. for a working day of eight hours). On these grounds, cycle parking provision should be of a high quality in terms of the protection from theft and weather provided. Since this cycle parking would be for the members of the public rather than, for example, private employees (where secure facilities may be accessible through controlled key/key card access), professionally guarded and sheltered cycle parking that public transport patrons can use could be particularly effective as a means to grow cycle-rail journeys that can substitute car use (see Egan et al., 2023, p.5, ‘Protection’) – which can be observed in high-cycling contexts (Martens, 2007; Pucher and Buehler, 2008). At present, the potential for synergistic integration of cycling and rail to substitute both the flexibility of the car and its speed over long distances has been grossly neglected. Instead, cycling appears to be mainly considered as a stand-alone mode, judging by the exposed and unprotected cycle parking provision at rail stations. On these grounds, some of the greatest opportunities to grow public transport ridership and cycle-rail car substitution journeys may lie first and foremost with retrofitting guarded and sheltered parking into high-density existing rail stations, which may be best achieved first and foremost by reallocating car parking space for cycle parking – in keeping with broader road space reallocation strategies for generating modal shift.

C16: Agriculture

The importance of sociological approaches in researching the relationship of certain groups to Ireland’s climate actions is particularly evident when looking at farmers. A review of the agricultural literature in this area shows strong sociocultural dimensions to the life of the farmer that extend beyond profitability and incentives to farming as ‘a way of life’ (Hammersley et al., 2023). The anchored nature of land ties many in this group into the world of the ‘local’ where opinions of neighbouring farmers matter, where practical local knowledge is valued (McDonagh et al., 2020), and where there are stronger ancestral and familial bonds, reinforced by the dominance of patrilineal inheritance through which farm-holders are predominantly male (13% are women). Common themes emergent from these systems of factors include the importance of farmer autonomy and independence (Hammersley et al., 2021), and the cultural status of what academics term the ‘good farmer’, which can incorporate notions of farming tidiness (Burns, 2021) as well as ‘scale’ – depending on the sector. Often these conflict with agri-environmental schemes and subsidies. A particular grievance is a sense of being hindered from displaying valued skills as a farmer and from having farmer insights excluded or marginalised in the implementation of policies or schemes (Hammersley et al., 2021; Harrahill et al., 2022; McDonagh, 2022). On these grounds, efforts to properly include local farmer knowledge and provide opportunities to demonstrate farmer skills and values (e.g., results-based approaches) would help with encouraging more environmental farming and land use. In addition, consideration of gender in agriculture should also be given priority. Women constitute a significant shareof farmers, nationally and globally. In the EU, approximately 29% of farms are managed by women (Eurostat, 2016). Only 13% of farmholders in Ireland are women (CSO, 2021). Female farmers also often work without visibility and status, seriously affecting farm succession and social sustainability. In the plans to develop a circular bioeconomy, consideration of gender should be given a key priority.

C20: The Circular Economy and Other Emissions

The vast consumption and rapid obsolescence of digital electronics and small and mobile devices have not only led to growing concerns about resource consumption and depletion but also end-of-life electronic waste, or e-waste, management. In 2022, a record 62 billion kg of e-waste was generated globally – equivalent to an average of 7.8 kg per capita per year – and only 22.3 per cent of this e-waste was documented as formally collected and recycled in an environmentally sound manner.[1] Ireland should continue to lead in terms of preventing the creation of e-waste as a priority, contributing to the efficient use of precious rare-earth resources and the retrieval of secondary raw materials through re-use, recycling and other forms of recovery, and improving the environmental performance of organisations involved in the entire life cycle of such e-waste. Of particular concern is the very poor rate of return of used and discarded smart and mobile phones, tablets, and laptops. In particular, as living standards increase, consumption and therefore waste (including e-waste) are also likely to continue to increase. A priority should be to encourage and support government-backed and private operators of take-back schemes for such small portable electronic devices to establish partnerships with reuse and waste organisations to give them access to collected electronics, to enable the separation of those that can be prepared for reuse from those that are sent for recycling, and the setting of binding reuse and preparing for reuse targets for all mobile service providers.


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Kind regards

The SAI Environment & Society Study Group:

Dr Emmet Fox, South East Technological University; Dr Egle Gusciute, University College Dublin; Dr Michael Hynes, University of Galway and Dr Robert Egan, Trinity College Dublin.