Published: 7th JANUARY 2020

Sustrans in N.Ireland’s response to the Environment Strategy consultation

We believe an Environment Strategy is just as important as the other Executive-endorsed strategies. Given it is the first time such a strategy has been developed in Northern Ireland and the current threats to the environment, it needs to be given the same importance.

Q1: Do you agree that the Environment Strategy should sit alongside existing Executive-endorsed strategies, such as the Sustainable Development, Public Health and Economic Strategies?


We believe an Environment Strategy is just as important as the other Executive-endorsed strategies. Given it is the first time such a strategy has been developed in Northern Ireland and the current threats to the environment, it needs to be given the same importance. This is particularly critical with decisions taken within the Department for Infrastructure, with respect to budgetary decisions around roads infrastructure development, public transport, and walking and cycling infrastructure including greenways.

We would like to see a set of ambitious, accountable targets for the Strategy to have some direction. For this document to have any impact it will require an Environment Bill to be passed in Northern Ireland.

We urge politicians and particularly a future Environment Minister to work with DAERA officials to extend the provisions of the Environment (Principles and Governance) Bill to Northern Ireland.

Q2: Do you agree that these broad environmental areas are appropriate for the Environment Strategy?


There is some overlap between the two themes: Environmental Quality and the Built Environment. It is good to see planning, housing and regeneration included as an environmental area. We need to see policies developed that can be properly measured to improve the environment. For example, car parking has a huge impact on urban environments, air quality and the health of citizens. Councils have produced car parking strategies mainly to understand capacity but with little consideration for the environmental impact of cars entering busy urban centres and residential areas. The Environment Strategy must provide appropriate guidance and measures to tackle the blight of car parking across Northern Ireland, so that there is sensible provision to make towns and cities more liveable.

Transport should be mentioned within the ‘Environmental Quality’ area. Just like litter and dog fouling, traffic has a significant physical impact on the environment in which we all live. It should not be assumed that transport falls incidentally within other areas like air quality or built environment.  It needs specific mention in Environmental Quality due to the impact vehicles have on the way people and biodiversity is managed.

Q3: Do you agree that these are appropriate strategic themes for the Environment Strategy?


Q4: Do you have any comments on what specific issues should be included under a proposed Environmental Engagement strategic theme?

This theme is particularly relevant to the behaviour change work Sustrans does in Northern Ireland.


In the rush hour, as many as one-fifth of all journeys are parents doing the school run, despite the fact that most primary school children live within a very walkable one mile of their school. The majority of primary age children in Northern Ireland, 61% are driven to school. The Active School Travel programme we deliver provides schools with the skills and knowledge to get more children walking, cycling and scooting as their main mode of transport to school. This helps reduce congestion and air pollution around school gates. The programme is funded jointly by the Department for Infrastructure and the Public Health Agency. However, it has a positive impact on the environment and therefore could also be supported by DAERA. Given the success of the programme, it should be expanded to support more schools with additional funding and include an element to improve infrastructure where this is highlighted as an issue.

To cite just one year’s evidence of impact: In the school-year 2018-19, the number of children walking, cycling and scooting to school at participating schools increased from 35% to 53%. At the same time, the number of pupils being driven to school fell from 58% to 41%.

It is important to note that while engagement with young people is vital from an early age, we must not ignore educating older generations about the environment and the impact less driving can have on the areas we live in.

General public awareness

Air pollution is often invisible with residents in heavily polluted areas not realising the extent of the problem and the resulting health impacts. As much as 23% of carbon dioxide emissions in N.Ireland come from transport. Some of the most concerning levels of NO2 emissions, which largely come from diesel engines, were recorded across inner-city working-class communities, with heavy traffic prevalent.

We live in a car-dominated environment where there is low awareness of the effect driving has on our streets both in terms of safety and the liveability of an area. While there is increasing awareness from media coverage about the health impact of air pollution caused by diesel engines, there is a long way to go before the public changes their driving habits.

More than 70% of all journeys in Northern Ireland are by car and many of these journeys are single-occupant car journeys. Just 5% of all journeys are by public transport.[1]

Outside of schools, we work in two other key areas – workplaces and community settings – to encourage people to reduce the journeys they make by car and promote active travel. Both programme areas are fully funded by the Public Health Agency (PHA). The strategic outcomes have an impact on the environment in terms of improving air quality, reducing congestion, freeing space that would otherwise be taken up by car parking. We currently employ just four officers in these areas, with a greater complement of staff this work could have a much bigger impact to improve the environment.

DAERA’s work with other government departments and councils

DAERA has a responsibility to work in partnership with other government departments and councils to tackle air pollution levels and protect the environment. This is acknowledged in the Draft Programme for Government but we would like to see more meaningful cross-departmental collaboration to fund and support projects that are having a positive impact on the environment. To this end, a Clean Air Act is essential to provide specific targets and penalties to hold people and organisations to account.

Q5: Do you have any comments on what specific issues should be included under a proposed Environmental Prosperity strategic theme?

A ‘Green New Deal’ must be included in the Strategy to harness the benefits of carbon-free industries such as wind, water and solar power. We need to redefine what prosperity means. A healthy, sustainable environment should be prized above all and can reap economic benefits.

As a society, we have been underestimating the cost of driving to the environment and our health for decades. A European Commission study in 2018 examined the negative effects that transport has on the environment, health, air quality and climate. Taxes and charges paid by transport users cover less than half the true cost when infrastructure and the external costs of accidents, climate change, air pollution and noise are considered. This is a Europe-wide cost of about €1tn (£680bn) – about 7% of the economy. Three-quarters is due to road transport. The flipside of this is that the traditional view of transport systems does not value the exercise gains from walking and cycling that make them cost-beneficial to society.

We must build Northern Ireland’s clean green image as an attractor for inward investment, recognising the economic and tourism potential inherent in our natural heritage. Tourism is a growing sector in Northern Ireland with obvious economic benefits. However, it is dependent on maintaining our beautiful countryside. There is a challenge to ensure we get the balance right between promoting the environment and not over-exploiting it. Encouraging cycle tourism, supported by expanding the network of greenways in Northern Ireland, is an important market to consider. Cycle tourism is less damaging to the environment than alternative forms of transport such as coaches and private cars.

It is disappointing the discussion document refers to the environmental damage leisure activities, including cycling can have, but there is no mention of those choosing to use polluting vehicles which by comparison is hugely damaging to the environment and our health.

We also have evidence that greenways promote local business and have spearheaded tourist booms elsewhere in Ireland e.g. the Great Western Greenway and the Waterford Greenway. Northern Ireland must do more to fund and develop our greenway offer. The Department for Infrastructure published a Strategic Plan for Greenways in 2016. This earmarked £150 million over 25 years to create new traffic-free routes or greenways connecting communities across Northern Ireland. It aligns with Sustrans own vision of a traffic-free National Cycle Network for Northern Ireland. However, aside from feasibility studies, progress on this strategy has stalled. This needs to have buy-in and support from the Executive at the highest level as it has huge benefits on a wide range of levels across society, the environment and the economy.

Q6: Do you have any comments on what specific issues should be included under a proposed Environmental Efficiency strategic theme?

It is unacceptable there is no specific climate change legislation in Northern Ireland. Legislation for climate change would allow specific policies to be developed to meet emissions targets and adapt our environment to the risks.

A clear target to decarbonise our energy supply and achieve net-zero carbon emissions as soon as possible, and certainly by 2045.

We need to properly cost the impact of driving private cars on the environment and our health e.g. NO2 emissions and particulate emissions. DAERA needs to work more closely with DfI to implement an Environment Strategy that discourages private car use; ensures cleaner engines; proper testing of vehicle emissions; redirects transport budgets towards public transport, walking and cycling. Modal shift requires not just infrastructure investment but spending on behaviour change initiatives as outlined above.

Resource Efficiency – we would like to see a shift in land-use practices towards a system that rewards farmers public money for public goods/biodiversity improvements, rather than subsiding current inefficient and sterilising agricultural practices i.e. Sustainable Production and Consumption.  Land use practices should support the creation of green corridors for biodiversity, creation of green infrastructure such as greenways and paths for walking and cycling between towns and villages.

We need to develop and implement policies that work across all government departments to promote the development of a circular economy and realise the economic benefits and opportunities this can provide. This will depend upon not merely sufficient dedication of financial resources but also capacity building across all sectors.

Q7: Do you have any comments on what specific issues should be included under a proposed Environmental Quality strategic theme?

We want to see a Clean Air Act for Northern Ireland.

Over 60 years ago, the Clean Air Act came into force tackling the pollution caused by fires in people’s homes. We now face a challenge on a similar scale largely as a result of motor-traffic. We support Client Earth in calling for new clean air legislation of the scale and scope reflecting the challenges we face today. Such legislation would include:

  • Tackling the sources of modern air pollution – motorised vehicles.
  • Safeguard legal protections to breathe clean air that we could lose, leaving the EU.
  • Adopt more ambitious air quality standards, based on the latest scientific evidence.
  • Be backed up by an independent watchdog with the power to take action.

We welcome the inclusion of Environmental noise as a theme. More research is required in this area and more needs to be done to tackle the high levels of noise people suffer particularly in urban areas and those living close to major roads. Traffic noise can also be a factor in what should be quieter residential streets with drivers using routes as ‘rat-runs’ to avoid busier roads.


Greenways are an important contributor to biodiversity and habitat in both rural and urban settings. This is another reason for ensuring the DfI’s Strategic Plan on Greenways is fully realized.

We agree with Northern Ireland Environment Link’s (NIEL) assertion that: “Ambition needs to be raised beyond ‘halting’ biodiversity loss to ‘halting and reversing’ biodiversity loss given the current depleted state of wildlife in Northern Ireland. There is a need for an ambitious and well-resourced Environmental Recovery Plan to be developed which can translate the Strategy into action commensurate with the scale of the challenge.”

Neighbourhood quality

This is an important theme which cannot be underestimated. In order to encourage people to get outdoors and enjoy their environment by walking and cycling, the quality of their local neighbourhood is vital. Dog fouling, litter, anti-social behaviour and general dilapidation can lead to an amenity being neglected, under-used and then eventually abandoned.

Behaviour Change initiatives such as our One Path Initiative have successfully promoted good citizenship values on shared paths such as the Comber Greenway. Similar behaviour change programmes should be considered to tackle the issues under this theme.

It is critical that within the ‘Environmental Quality’ strategic theme that the dependence of our society on cars for short journeys is acknowledged as a major contributing factor that can contribute to a loss of amenity for local residents and visitors, and a range of social and economic problems such as increased anti-social behaviour, reduced trade and tourism, and health issues.  This should be expressed with the same or greater emphasis to the already listed contributors including litter, dog-fouling, environmental noise, dilapidation, graffiti, and fly-posting. Cars and other polluting vehicles contribute greatly to amenity degradation through (not limited to) illegal and inconsiderate parking, speeding, and general inequity of allocation of space.

Q8: What do you see as the main environmental governance priorities for Northern Ireland?

We live on a small island and a short distance across the Irish Sea to Great Britain. Environmental issues, in particular, air pollution know no borders. To that end we want the new independent body - the Office for Environmental Protection (OEP) - to have powers in Northern Ireland. We believe a UK-wide body is best placed to ensure environmental standards are adhered to across the whole country. This will also be an essential post-Brexit to address roles currently undertaken by EU institutions. We are concerned about the implications of Brexit and recognise it is a fluid situation at the moment.

We also must have close cooperation with environmental bodies in the Republic of Ireland.

As recommended by various reports over the years we support an Independent Environment Protection Agency for Northern Ireland.

Q9: Do you agree that these are appropriate draft outcomes for the Environment Strategy?


All these draft outcomes must be backed up by ambitious targets and properly monitored and implemented or it will be a fruitless strategy.

Need to be ambitious in statements: e.g. there needs to be more urgency in this statement. We suggest:

‘We ‘dramatically’ reduce greenhouse gas emissions and ‘vastly’ improve climate resilience’

Q10: What are your big ideas for the future protection and enhancement of the environment?

20-Minute Neighbourhood planning reform

We want to see this planning principle enshrined in all new developments so all people living in cities and towns are within a 20-minute walk from their everyday services. This may require an Active Travel Act, similar to what Wales has implemented, to give this statutory authority. We propose that local authorities are helped to unlock sites for 20-minute neighbourhoods to provide the essential amenities close to people’s homes to reduce dependence on cars. This may also require new Planning Practice Guidance on walking and cycling and a Transforming Places Fund to support the development of 20-minute neighbourhoods.

The results of this planning reform will improve people’s health and the environment. It will boost community cohesion and reduce social isolation. People more in touch with their local neighbourhood will cherish and respect their environment more. Tackling the over-reliance on private cars and the need for people to travel longer distances for essential services is vital to improve air quality, our health and the environment in general.

Sustained long-term investment in walking and cycling

For decades investment in walking and cycling has been piecemeal – the crumbs of a transport budget that focuses almost exclusively on roads and moving cars, not people.

We want to see at least 5% of the transport budget spent on walking and cycling by 2020/21, rising to at least 10% before 2024/25. This is imperative if we are to achieve the targets set out in the Northern Ireland Bicycle Strategy, published in 2015, which aimed to achieve 20% of all journeys less than 1 mile to be cycled. According to the latest Travel Survey for Northern Ireland, just 1% of all journeys are by bicycle.

By making it easier for people to walk and cycle, we will not only open up access to job opportunities; build more exercise into our daily lives; but help to address the climate crisis and air pollution by reducing car use.

Our dependency on using motor vehicles to get around has driven the climate change crisis. It costs the economy £7.9 billion a year through traffic congestion. And is the major cause of air pollution in our towns and cities. It is also contributing to greater levels of physical inactivity than we have ever seen before, costing the NHS £1 billion a year.


Roll out School Zones to encourage children to walk and cycle

The biggest concern of adults when it comes to children walking and cycling to school is traffic danger. There is now growing evidence of the impact of air pollution on young lungs which is caused largely by parents driving children to school and idling engines. We fundamentally need to address this issue to get more children making active journeys. As a default in School Zones, the roads and streets surrounding schools should have 20mph speed limits, and reduce through traffic so that cars are guests. These streets should be designed to act as direct and high-quality routes for children to walk, cycle or scoot to school. Where schools are located on busier, main roads, protected cycle paths should be installed. Sustrans’ work to transform local walking and cycling routes has increased children’s annual usage by 117% and delivered a 151% increase in children using the routes to get to school28. The Department for Transport (DfT) analysis shows that such investment offers extremely high value for money, returning at least £10 (including congestion, physical activity, and safety benefits) for every £1 invested.

Provide on-road cycle training for all school children

All 9 and 10-year-old children should be offered on-road cycle training in school or community settings. In the Netherlands, where 58% of children cycle to school, cycle training is introduced at an early age for virtually all children.

We need to promote active travel from a young age and equip a new generation with the skills to get about independently and without reliance on cars.

20mph default speed limit in all built-up areas

The chance of being killed is five times higher if hit at 30mph in comparison to 20mph. Slower speeds will increase safety and improve the environment making it feel less hostile to pedestrians and residents.

Pavement parking ban

Space in many urban places is becoming more and more constrained as car ownership rises, with many people choosing to park on pavements and other public space of the carriageway, such as grass verges. Vehicles parked on pavements make it difficult for people to use the footway. This includes people who are blind or partially sighted, older people, children, and people with reduced mobility, prams or pushchairs, who can be forced into the road and put at greater risk of collision and injury. The dominance of cars in our neighbourhoods greatly detracts from the environment and makes them less pleasant places to live and pass through. We believe Northern Ireland should follow the example of both London and Scotland and pass legislation to ban pavement parking.

People-prioritised streets and traffic restraint

People-prioritised streets and places put the needs of people first. This may or may not include elements typical of shared space schemes or give separate space to different users depending on which best creates an inclusive environment for all users.

We need more traffic restraint policies, including workplace car parking levies and mileage paid for cycling, along with other incentives to encourage modal shift to more sustainable modes of transport beneficial to the environment.

Develop a greenway network

Access to green and blue space is an essential human need. It improves our mental and emotional wellbeing, enables stronger social connections, and promotes physical activity.

A greenways programme that links towns and cities to green and blue space around them and provides direct, safe and attractive traffic-free walking and cycling routes, planned by the local community will go a long way to improving the problems which the UK population faces on a daily basis, and helping people incorporate encounters with the natural environment into their daily lives.

Trees absorb and store greenhouse gas emissions from cars, improve air quality, tackle noise pollution and provide shade in heatwaves. Good quality green and blue infrastructure including measures like Sustainable Urban Drainage Systems will better enable our towns and cities to cope with increased flood risk and weather changes, as well as improve our health and wellbeing.

Green citizens - volunteers

We need to galvanise the enthusiasm and commitment of citizens to protect and promote the environment. Sustrans has teams of volunteers who help us promote walking and cycling. We have a large number of rangers who look after the National Cycle Network and greenways across Northern Ireland – their work involves tidy days, signage and trouble-shooting. These volunteers should be given more support and a higher profile. There are many environmental charities across Northern Ireland that have similar teams of volunteers helping to support their work. A national programme, supported by government, should be considered to attract a network of ‘green’ volunteers, of all ages, to improve engagement with and the protection of our environment, as we all have a stake in it.

[1] Travel Survey for N.Ireland, Dept for Infrastructure

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