COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review Country Report - IRELAND Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Ireland, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 260 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review     Country Report - IRELAND           Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Ireland  1 

This report has been written by the staff of the Directorate-General for Environment, European Commission. Any 
comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs:  

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ireland  2 

Table of Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 3 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 8 
Nature protection and restoration ....................................................................................................................... 8 
Marine ecosystems............................................................................................................................................. 14 
Ecosystem assessment and accounting ............................................................................................................. 15 
3. ZERO POLLUTION ..................................................................................................................................................... 17 
Clean air ............................................................................................................................................................. 17 
Industrial emissions ............................................................................................................................................ 18 
Major industrial accidents prevention – SEVESO ............................................................................................... 20 
Noise .................................................................................................................................................................. 21 
Water quality and management ........................................................................................................................ 21 
Chemicals ........................................................................................................................................................... 25 
4. CLIMATE ACTION ..................................................................................................................................................... 28 
Key national climate policies and strategies ...................................................................................................... 28 
Effort sharing ..................................................................................................................................................... 28 
Key sectoral developments ................................................................................................................................. 29 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 30 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 31 

5. FINANCING ............................................................................................................................................................. 31 
Environmental investment needs in the European Union .................................................................................. 31 
EU environmental funding 2014-2020 ............................................................................................................... 32 
EU environmental funding 2021-2027 ............................................................................................................... 34 
National environmental protection expenditure ................................................................................................ 35 
Green budget tools ............................................................................................................................................. 36 
Overall financing compared to the needs .......................................................................................................... 38 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 40 
Information, public participation and access to justice...................................................................................... 40 
Compliance assurance ....................................................................................................................................... 42 
Effectiveness of environmental administrations ................................................................................................ 43 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 44 
TAIEX EIR peer to peer ........................................................................................................................................ 44 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
Ireland  3 

Executive summary 

In previous environmental implementation reviews (EIRs), 
identified  four  main  challenges  for 
the  Commission 
Ireland’s implementation of EU environmental policy and 
law. These challenges were: 

  completing  the  Natura  2000  designation  process  for 

terrestrial and marine sites; 
further protecting raised and blanket bogs; 

 
  maintaining  the  significant  investments  required  for 
water  treatment,  given  the  urgent  need  to  invest  in 
water infrastructure; 
Improving access to justice in environmental matters 

 

Ireland  has  made  progress  in  designating    nature  sites 
within its terrestrial Natura 2000 network under the Birds 
and  Habitats  Directives  and  the  terrestrial  designations 
are now considered to be complete. It has also made some 
progress in drawing up conservation objectives. However, 
there  is  still  a  lack  of  clarity  over  Ireland’s  conservation 
measures.  There  are 
significant  knowledge  and 
designation gaps in Ireland’s marine Natura 2000 network, 
especially under the Birds Directive. Delays in finalising the 
list  of  sites  of  community  importance  (SCIs),  and  the 
designation  of  marine  special  protection  areas  (SPAs) 
under the Birds Directive are of particular concern given 
that many of these areas are likely to be under pressure 
for  development.  The  situation  for  forested  areas 
protected  under  the  nature  directives  is  concerning  as 
over half of assessments show a bad conservation status. 

There are still concerns about the conservation of raised 
and  blanket  bogs  designated  as  special  areas  of 
conservation  (SACs),  which  remains  the  subject  of  an 
infringement procedure. In recent years, Ireland has made 
significant  progress  by  drawing  up  a  national  peatlands 
strategy and national raised-bog SAC management plan. It 
has also improved the protection of raised-bot  sites and 
blanket-bog sites and has begun to restore the former, in 
particular  through  several  LIFE  projects.  However, 
restoration work has still to be completed on many raised-
bogs  SACs  and  started  on  most  blanket-bog  SACs. 
Moreover, illegal turf cutting still takes place on raised-bog 
SACs and Ireland has not made any progress in ensuring 
that  turf  cutting  carried  out  in  blanket-bog  SACs  is 
managed 
is  compatible  with  the 
in  a  way  that 
conservation of this habitat.  

Water treatment continues to be a concern. There is a low 
compliance  rate  with  the  Urban  Wastewater  Treatment 
Directive  due  to  the  large  number  of  non-compliant 
agglomerations, in particular further efforts are needed to 
provide  biological  treatment  to  additional  50.5%  p.e  of 
urban  waste  water,  as  well  as  biological  treatment  to 

remove nitrogen and/or phosphorusfrom a further 75.1% 
p.e.  of  urban  waste  water.  Ireland  has  not  yet  resolved 
problems with its drinking water. The quality of Ireland’s 
bathing waters is below average. The country’s new water 
pricing system requires monitoring to ensure that it works 
in practice. The powers to regulate water abstraction and 
hydromorphological  controls  are  still  not  in  place  as  the 
proper legal framework is still absent. 

Access  to  justice  in  environmental  matters  remains  an 
issue and no progress has been achieved since the last EIR 
in 2019. The Commission is concerned about the cost of 
bringing  an  environmental  legal  action  in  Ireland,  which 
remains a very significant obstacle to access to justice, as 
well as other obstacles to legitimate access to justice for 
environmental reasons. 

On waste policy, Ireland’s waste generation continues to 
riseand  remains  significantly  above  the  EU  average. 
Ireland’s landfilling and recycling rates for municipal waste 
and packaging waste have declined since 2014, with more 
waste  being  sent  for  energy  recovery..  The  recently 
adopted waste action plan for a circular economy aims to 
improve  the  country’s  performance,  but  the  updated 
waste  management  pPlan  in  line  with  the  new  Waste 
Framework Directive has not been adopted yet. Although 
Ireland  is  well  above  EU  average  in  terms  of  resource 
productivity, it’s circular (secondary) use of material is the 
second lowest in the EU. 

On  air  quality,  Ireland  has  made  some  progress  in 
reducing emissions. However, emissions of ammonia have 
been 
since  2011;  ammonia  emissions 
particularly from agriculture pose a significant problem. 

increasing 

its  environmental 

EU  financing  continues  to  help  Ireland    substantially  in 
implementation  gap,  and 
tackling 
Ireland is due to have received over EUR 989 million from 
its  recovery  and  resilience  plan  (RRP)  (2021-2026)  in 
grants  and  EUR  1.19  billion  from  cohesion  policy  (2021-
Ireland’s  overall  environmental  financing  for 
2027). 
investments  is  estimated  to  have  been    0.3%  of  GDP  in 
2014-2020,  mostly  from  national  sources.  The  country’s 
environmental investment needs in 2021-2027 amountto  
  0.48%  of  GDP,  suggesting  a  potential 
at 
environmental  financing  gap  of    over    0.18%  of    GDP,  if 
baseline  financing levels continue.   

least 

Since  2019,  Ireland  has  had  to  pay  fines  of  over  EUR  13 
million  imposed by the  Court of Justice of the European 
Union  for  non-conformity  with  environmental  impact 
assessment (EIA) legislation.  

Environmental Implementation Review 2022 – Ireland 

 
 
 
Ireland  4 

Part I: Thematic areas 

1. Circular economy and waste management

Measures towards a circular economy 

Figure 1: Circular material use rate (%), 2010-20201 

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve the EU’s 2050 climate neutrality target and to halt 
biodiversity  loss.  The  Action  Plan  announces  initiatives 
along the entire life cycle of products, aiming to reduce the 
EU's consumption footprint and to double the EU's circular 
material  use  rate  by  2030.  It  targets  how  products  are 
designed,  promotes 
circular  economy  processes, 
encourages sustainable consumption, and aims to ensure 
that waste is prevented and the resources used are kept 
in the EU economy for as long as possible.  

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity  rate  exist  between  countries.  To  help  achieve 
the goal in the EU circular economy action plan of doubling 
the  EU’s  circular  material-use  rate  by  2030,  ambitious 
measures  targeting  the  whole  product  life  cycle  are 
needed at Member State level. Such measures range from 
sustainable  product  design  that  makes  it  possible  to 
increase  the  durability,  reparability,  upgradability  and 
recyclability  of  products,  to  other  measures,  like:  (i) 
‘remanufacturing’; (ii) increasing circularity in production 
processes; (iii) recycling; (iv) boosting eco-innovation; and 
(v) increasing the uptake of green public procurement. 

Ireland’s circular (secondary) use of material i was 1.7 % in 
2016 and was 1.8 % in 2020, compared to the EU average 
of  12.8%.  As  its  growth  was  lower  than  that  of  the  EU 
overall, the gap to the EU average has widened. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  minimise 
impacts  on  the  environment  and  reduce 
negative 
dependency on volatile raw material markets. As shown in 
figure  2,  with  EUR  3.13  generated  per  kg  of  material 
consumed in 2020, resource productivity in Ireland is well 
above  the  EU  average  of  EUR  2.09  per  kg.  This  positive 
performance 
is  further  supported  by  a  continuous 
increase in the resource productivity of Ireland over the 
last decade. 

Figure 2: Resource productivity, 2010-20202 

1 Eurostat, Circular Economy Monitoring Framework. 

2 Eurostat, Resource productivity. 

Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
 
 
Circular economy strategies  

The Commission encourages Member States to adopt and 
implement  national/regional circular  economy strategies 
covering the whole life cycle of products. This is because 
such  strategies  are  one  of  the  most  effective  ways  to 
progress  towards  a  more  circular  economy  at  Member 
State  level.  Since  the  launch  of  the  online  European 
Circular Economy Stakeholder Platform in 20173, national, 
regional  or  local  authorities  have  used  the  platform  to 
share their strategies and roadmaps.  

A  ‘whole  of  government  circular    economy  strategy’ 
published in December 2021 is set to replace the current 
suite of policies, plans and programmes.. 

Moreover, in September 2020, the Government adopted 
a  ’Waste  Action  Plan  for  a  Circular  Economy’,  the  new 
national  waste  ction  plan  for    2020-2025.  The  policy 
document  contains  over  200  measures  across  various 
waste  areas 
including  municipal  waste,  consumer 
protection  and  citizen  engagement,  plastics  and 
packaging,  construction  and  demolition,  textiles,  green 
public procurement and waste enforcement. Ireland does 
not  have  specific  sectoral  strategies 
for  plastics, 
construction  or  textiles,  however  these  sectors  are 
targeted  in  the  circular  economy  programme  (formerly 
know as the national waste prevention programme) led by 
the Environmental Protection Agency (EPA), as well as the 
waste action plan for circular economy. 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the full 
potential  of  the  circular  economy  can  only  when  it  is 
implemented  across  all  value  chains.  Therefore,  eco-
innovation is an important enabling factor for the circular 
economy.  New  approaches  to  product  design  and  new 
business models can help to produce systemic circularity 
innovations, creating new business opportunities. 

The country ranked 14th in EU scoring 109 in the 2021 Eco-
Innovation  Scoreboard4,  resulting  in  an  average  eco-
innovation leader performance status. In two out of five 
components  of  the  2021  Eco-innovation  index  ,  Ireland 
performs above the EU average, namely in eco-innovation 
activities  and  resource  efficiency  outcomes,  while,  its 
performance  is  below  the  EU  average  in  eco-innovation 
inputs,  eco-innovation  outputs  and  socio-economic 
outputs. 

Ireland  5 

Figure 3: Eco-innovation performance, 2010-20195 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14%  of  EU  GDP. 
Public  procurement  can  help  drive  the  demand  for 
sustainable  products 
reparability  and 
recyclability standards.  

that  meet 

in 

lead  role 

In  Ireland,  a  national  action  plan  –  ‘Green  Tenders’  (Jan 
2012)  was  published  by  the  Department  of  the 
’greening‘ 
Environment,  who  has  the 
procurement across the Irish public sector. In September 
2021 the EPA published a national guidance document for 
the public sector6. In addition, the EPA  published its first 
monitoring report on GPP in 18 government departments 
which  collates  and  reports  on  activities  and  data7.  In 
October 2019, Circular 20/20198 was published to support 
the  climate  action  plan  by  promoting  the  wider  use  of 
in  public 
environmental  and  social  considerations 
procurement.  Ireland  has  committed  to  implementing 
GPP in all tenders that involve public funds by 2023. This 
transition  is  being  supported  through  guidance  and 
training.  Moreover,  the  EPA  takes  the  lead  on  the 
monitoring and reporting of government procurement by 
government departments.  

3  Circular Economy Stakeholder Platform 
4 https://ec.europa.eu/environment/ecoap/indicators/index_en 
5 European Commission - Directorate-General for Environment (DG ENV), 
Eco-innovation Observatory’, Eco-innovation index. 
6 Green Public Procurement | Environmental Protection Agency (epa.ie) 

7 Resources | Environmental Protection Agency (epa.ie) 
8  gov.ie  -  Circular  20/2019  :  Promoting  the  use  of  Environmental  and 
Social Considerations in Public Procurement (www.gov.ie) 

 Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
 
 
EU Ecolabel and the eco management and audit scheme 
(EMAS) 

The number of EU Ecolabel products and EMAS-licensed9 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy.   

to 

As of September 2021, Ireland had 171 products out of 83 
590,  and  21  licences  out  of  2  057  registered  in  the  EU 
Ecolabel scheme, showing a very low take-up of products 
and licences10. Moreover, one organisation, amounting to 
one  site  from  Ireland  is  currently  registered  in  EMAS, 
down from three sites in 201911. Figures for Ecolabel have 
improved,  with  136  new  product  and  16  new  licence 
registrations under the EU Ecolabel. 

Overall, Ireland has made good progress in strengthening 
its circular economy policy framework, having developed  
a  new  comprehensive  strategy.  However,  its  circular 
material use rate is far below the EU average, so a priority 
action is proposed. 

2022 priority actions  

  Adopt the national circular economy strategy 
  Adopt measures to improve the circular  material use 

rate 

Waste management 

Turning waste into a resource is supported by:  
(i) fully implementing EU waste legislation, which includes 
the  waste  hierarchy,  the  need  to  ensure  separate 
collection of waste, the landfill diversion targets, etc.;  
(ii) reducing waste generation and waste generation per 
capita in absolute terms;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This section focuses on management of municipal waste12 
for which EU law sets mandatory recycling targets. 

9  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
10 European Commission, Ecolabel Facts and Figures. 
11  However,  it  should  be  noted  that  several  Irish  companies  have  ISO 
accreditation for their EMAS. 
12  Municipal waste consists of (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 
plastics,  bio-waste,  wood,  textiles,  packaging,  waste  electrical  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
including  mattresses  and  furniture;  (b)  mixed  waste  and 
waste, 

Ireland  6 

Preventing products and materials from becoming waste 
for as long as possible is the most efficient way to improve 
resource  efficiency  and  to  reduce  the  environmental 
impact of waste. Waste prevention and product re-use are 
the  most  preferred  options  under  the  waste  hierarchy. 
The revised Waste Framework Directive adopted in 2018 
sets new obligations on waste prevention and introduces 
more effective waste prevention programmes. 

The  generation  of  municipal  waste  per  capita  in  Ireland 
decreased  significantly  in  2020,  with  555  kg  per  capita 
after  a  relatively  steady  increase  over  2014-2019.  The 
the  national  circular 
stringent 
economy  programme  might  partly  explain  this  positive 
outcome. Still, the amount of municipal waste generated 
per capita remains considerably above the EU average of 
502 kg. 

implementation  of 

In November 2021, Ireland has published a climate action 
plan13 which includes specific targets, including reductions 
in household waste, landfill use, plastics and food waste, 
and  sets  recycling  targets  for  municipal,  plastic  and 
packaging waste. 

Figure 4: Municipal waste by treatment in Ireland, 2010-
202014 

Between 2010 and 2020 Ireland substantially reduced its 
landfill rate from 53 %15 to 22.5 %, albeit with an upward 
trend over the last two years. In the meantime Ireland has 
strongly shifted towards incineration as waste treatment, 

separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Directive 
2008/98/EC, Art. 3 2b). 
13 Irish  Department  of  the  Environment,  Climate  and Communications, 
Climate Action Plan 2021. 
14  Eurostat, Municipal waste by waste operation, April 2022. 
15 
EPA 
https://www.epa.ie/publications/monitoring--
assessment/waste/national-waste-statistics/EPA_NWR_2010.pdf 

according 

data 

58% 

the 

to 

 Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
Ireland  7 

early  warning  reports  as  well  as  an  analysis  of  progress 
towards  achieving  the  2025  waste  recyling  targets.  This 
report  will  be  presented  at  the  end  of  202218  and  will 
assess  the  progress  made  to  date,  and  will  make 
recommendations as appropriate. 

Implementation of the 2018 waste legislative package 

Ireland  has  notified  the  transposition  of  the  2018  waste 
package19 to the Commission. A conformity assessment is 
ongoing. 

Waste  management  plans  and  waste  prevention 
programmes are instrumental for the full implementation 
of EU waste legislation. These plans and programmes set 
out key provisions and investments to ensure compliance 
with existing and new legal requirements (e.g.  on  waste 
prevention;  on  separate  collection  for  certain  waste 
streams,  on  recycling  and  on  landfill  targets).  Revised 
plans and programmes were due on 5 July 2020.  

Ireland  has  not  notified  its  updated waste  management 
plan,  however,  a  new  national  waste  management  plan 
for a circular economy is being prepared by the  regional 
waste  management  planning  offices  with  a  view  to 
completing and publishing it by end 2022 .  

2022 priority actions 

 

Introduce  new  policy 
including 
economic instruments, to promote prevention, make 
reuse and recycling more economically attractive. 

instruments, 

  Shift  reuseable  and  recyclable  waste  away  from 

 

incineration and landfilling. 
Increase  recycling  rates  by  making  the  separate 
collection obligation more effective. Carry out a review 
of recent reforms to the waste collection market. 
  Ensure that a waste management plan in line with the 

revised Waste Framework Directive is in place. 

the  rate  rising  from  4  %  in  2010  reaching  46  %  in  2019, 
although  this  fell  to  32  %according  to  the  provisional 
figures  for  2020.  This  trend  has  continued  since  the  last 
EIR report in 2019, where the risk of  not meeting the post 
2020 recycling targets due to increasing incineration had 
already been highlighted. 

Ireland’s recycling rate of municipal waste has increased 
in recent decades, but with 40.5 % in 2020, it still remains 
below  the  EU  average  of  48 %.  This  shows  that  Ireland 
needs to step up investment in recycling to meet the EU 
2025 recycling targets. Ireland’s   waste action  plan for a 
circular  economy  attempts  to  improve  waste  recycling16 
(making  all  packaging  reusable  or  recyclable  by  2030, 
introducing a waste recovery levy to encourage recycling, 
reviewing  government  support  for  the  development  of 
recycling infrastructure etc.). 

Figure 5 shows that Ireland needs to step up investment 
in  recycling  to  meet  the  EU  2020  and  2025  recycling 
targets. 

Figure 5: Recycling rate of municipal waste, 2010-202017 

The Commission's 2018 Early Warning report'12 did not list 
Ireland as one of the countries at risk  of  missing the EU 
2020  target  of  recycling  50 %  of  municipal  waste.  The 
Commission  is  currently  finalising  its  analysis  of  the 
progress  made  on  the  recommendations  from  the  2018 

16 Irish Department of the Environment, Climate and Communications, 
Waste Action Plan for a Circular Economy. 
17  Eurostat, Recycling rate of municipal waste, April 2022. 

19  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up to 
2035. 

 Environmental Implementation Review 2022 – Ireland 

 
 
                                                                 
 
 
 
 
2. Biodiversity and natural capital

Ireland  8 

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and sets out new targets and governance mechanisms to 
achieve healthy and resilient ecosystems.  
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s protected 
areas, including all remaining EU primary and old-growth 
forests;  
(iii) effectively manage all protected areas, defining clear 
conservation  objectives  and  measures,  and  monitoring 
them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore degraded ecosystems across the EU by 2030, and 
manage them sustainably, addressing the key drivers of 
biodiversity loss. 

The EU’s Habitats and Birds Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy  for  2030  and  are  the  cornerstone  of  the 
European  legislation  aimed  at  conserving  of  the  EU's 
wildlife20.  

Ireland’s third  national biodiversity action plan21, for the 
period 2017-2021, sets out actions to be carried out by a 
range of government, civil and private sectors in order to 
achieve Ireland’s ‘Vision for Biodiversity’. This follows on 
from  the  work  of  the  first  and  second  national 
biodiversity action plans. 

It  has  been  developed 
line  with  the  EU  and 
in 
international  biodiversity  strategies  and  policies.  The 
fourth  national  biodiversity  action  plan  is  currently  in 
development. 

Nature protection and restoration  

Natura  200022,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
in  the  Birds  and  Habitats 
achieve  the  objectives 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 
importance  (SCIs)  as  special  areas  of  conservation 
(SACs)23; and  (iii)  the  setting of conservation objectives 
and measures for the Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Ireland hosts 59 habitat types24 and 60 species25 covered 
by  the  Habitats  Directive.  The  country  also  hosts 
populations  of  42  bird  taxa  listed  in  Annex  I  the  Birds 
Directive 26. 

By 2021, 13.2 % of the national land area of Ireland was 
covered by Natura 2000 (EU average 18.5 %), with special 
protection  areas  (SPAs)  classified  under  the  Birds 
Directive  covering  6.2 %  (EU  average  12.8 %)  and  SCIs. 
under the Habitats Directive covering 10.2 % (EU average 
14.2 %) of Ireland’s territory. 

into  account  both  Natura  2000  and  other 
Taking 
nationally  designated  protected  areas,  Ireland  legally 
protects  13.9%  of  its  terrestrial  areas  (EU-27  average 
26.4%)  and  2.3%  of  marine  areas  (EU-27  average 
10.7%)27. Ireland rigourously protects 2.25% of the EU’s 
protected areas. 

On  the  basis  of  the  latest  update,  Ireland’s  terrestrial 
Natura  2000  network  under  the  Birds  and  Habitats 
is  now  considered  complete.  There  are 
Directive 

20 These should be reinforced by the Nature Restoration Law, according 
to the new EU Biodiversity Strategy. 
21https://www.npws.ie/sites/default/files/publications/pdf/National%
20Biodiversity%20Action%20Plan%20English.pdf  
22 
 Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive. 
Figures of coverage do not add up because some SCIs and SPAs overlap. 
‘Special Areas of Conservation (SACs)’ means an SCI designated by the 
Member States. 
23 
 Sites of Community Importance (SCIs) are designated pursuant to the 
Habitats  Directive,  whereas  Special  Protection  Areas  (SPAs)  are 

designated pursuant to the Birds Directive. Figures of coverage do not 
add  up  because  some  SCIs  and  SPAs  overlap.  Special  Areas  of 
Conservation (SACs) are SCIs designated by the Member States. 
24 EEA, Article 17 dashboard, Annex I total, 2019. 
25  EEA, Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex II + Annex V excluding those in Annex II, 2019. This counting only 
takes  into  account  species  and  habitats  for  which  assessment  of 
conservation status was requested. 
26 EEA, Article 12 dashboard, Annex I, 2020. This counting only takes 
into account birds taxa for which information was requested. 
27  European  Environment  Agency,  Protected  Areas,  terrestrial 
protected  area  percentage  (2021)  and  marine  protected  area 
percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Ireland 

 
                                                                 
Ireland  9 

Figure  7:  Natura  2000  terrestrial  protected  area 
coverage, 202129 

significant  knowledge  and  designation  gaps  in  Ireland’s 
marine Natura 2000 network, especially under the Birds 
Directive.  Delays  in  finalising  the  list  of  SSCIs,  including 
for  the  habitat  reefs,  as  well  as  poor  progress  in 
identifying,  selecting  and  designating  SPAs  under  the 
Birds  Directive  is  of  particular  concern,  given  the  very 
ambitious  plans  for  developing  renewables  in  offshore 
waters.  These knowledge and designation gaps must be 
addressed. 

Figure 6: Marine & terrestrial protected area coverage, 
202128 

Designating  SACs  and  setting  conservation  objectives 
and measures 

The Commission has submitted a case against Ireland to 
the EU Court of Justice in 202130 for failing to complete 
the designation of SACs under the Habitats Directive and 
the  establishment  of  the  necessary  conservation 
measures,  based  on  clearly  defined  conservation 
objectives.   

There are still concerns about the conservation of raised 
and  blanket  bogs  SACs,  which  is  still  the  subject  of  an 
infringement  procedure.  In  recent  years,  Ireland  has 
made  significant  progress  by  drawing  up  a  national 
raised-bog  SAC 
peatlands  strategy  and  national 
management  plan.  .  Moreover,  there  is  a  LIFE  project 
that  involves  12  raised-bog  SACs  and  a  LIFE  Integrated 
Project for managing of 24 blanket-bog SACs in Ireland. 
In  addition,  a  LIFE  integrated  project  called  ‘Peatlands 
and People’ is  underway, which will significantly restore 
and rehabilitate  peatlands in Ireland's midlands, bringing 
together best practices, as well as monitor and analyse 
carbon storage in the peatlands.   However, restoration 
work has still to be completed on many of the raised-bog 
SACs  and  started  on  most  blanket-bBog  SACs31.  Also, 

Furthermore,  the  LIFE  IP  Wild  Atlantic  Nature  project:  under  the 
INTERREG  VA  programme,  two  blanket  bog  projects  (‘Collaborative 
Action for the Natura Network’  and  ‘Cooperation across Borders for 
Biodiversity’)  are  focused  on  protecting  wetland  habitats,  including 
developing  conservation  action  plans  for  several  blanket-bog  SACs, 
restoration works and other management measures. The NPWS is also 
involved  in  a  public-private  partnership  blanket-bog  SAC  restoration 
project in one of its national parks, which will inform how restoration 
work will be done across a larger area covering approximately 20 000 
hectares. 

28  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
29  European  Environment  Agency  (EEA),  Natura  2000  Barometer, 
February 2022. 
30 Case C-444/21. 
31  In  total,  52%  (29  SACs)  of  the  raised-bog  SAC  network  have  had 
restoration  works  undertaken,  underway  or  preparatory  works 
completed.  In  addition  Ireland  is  restoring  sites  within  its  raised-bog 
natural  heritage  area  which  will  help  achieve  Ireland’s  national 
conservation target for active raised bog. 

Also,  the  agri-environmental    EIP  project  FarmPeat  funded  by  the 
Department of Agricullture, Food and the Marine is seeking to improve 
management of habitats on peat soils with a number of raised bog SACs 
included as project sites. 

Environmental Implementation Review 2022 – Ireland 

 
 
 
                                                                 
 
 
 
 
Ireland  10 

increased  to  15%.  The  main  pressures  are  agriculture, 
development  construction  and  related  infrastructure, 
invasive  alien  species,  changes 
in  water  regimes, 
forestry,  extraction of resources  (for habitats), and, for 
species,  extraction  and  cultivation  of  biological 
resources. 

Figure  8:  Assessments  on  conservation  status  for 
habitats  for  2007-2012  and  2013-2018  reporting 
periods34 

Figure  9:  Assessments  on  conservation  status  for 
for  2007-2012  and  2013-2018  reporting 
species 
periods35 

illegal turf cutting is still taking place in raised-bog SACs 
and Ireland has yet to make any progress in ensuring that 
turf cutting is carried out in these SACs in a way that is 
compatible  with  the  conservation  of  this  habitat.  For 
designated blanket bog sites domestic turf cutting on any 
new  banks  may  not  be  opened  or  commercial  peat 
extraction may not be undertaken on these sites without 
the prior consent of the Minister or the relevant consent 
authorities.  As  part  of  those  consenting  processes  the 
impact of the conservation objectives of the site should 
be assessed. 

Ireland  has  significant  conservation  issues  in  SPAs  and 
the  wider  landscape.  One  such  issue  is  the  dramatic 
decline of waders, particularly the curlew and dunlin, for 
which  there  have  been  declines  of  over  90 %  of  the 
breeding  populations 
in  recent  decades.  A  curlew 
conservation  programme  began  in  2017  and  a  LIFE 
project  for  machair,  which  will  include  actions  for 
breeding Dunlin in 2022. However, to halt the decline of 
breeding  waders,  conservation  action  is  needed  at  a 
landscape scale, including ongoing support for farmers to 
take  the  necessary  measures  as  well  as  ensuring  any 
forestry  practices  are  fully  compatible  with  protecting 
breeding  waders  and  their  habitats.  There  is  also  a 
continuing  need  to  reconcile  the  protection  of  the  hen 
harrier with forestry and wind-farm development32.  

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
towards  maintaining  or  restoring 
favourable 
the 
conservation status of species and habitats. 

According  to  the  report  submitted  by  Ireland  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article  17  of  the  Habitats  Directive  for  2013-2018,  the 
share of assessments for habitats in good conservation 
status  in  2018  was  15.25 %,  more  than  the  8.62 % 
reported  under  the  previous  reporting  period  (2007-
2012)33.  As  to  species  protected  under  the  Habitats 
Directive, the share of assessments  for these species in 
good  conservation  status  in  2018  was  56.67 %,  more 
than the 52.46 % reported under the previous reporting 
period (2007-2012).  

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation status decreased to 38.98% and the share 
of  assessments  for  species  in  bad  conservation  status 

In  conclusion,  some  improvements  in  the  status  of 
species  and  habitats  have  recently  been  reported  in 
Ireland, where targeted actions have taken place. 

32 A Hen Harrier threat response plan is due for public consultation in 
2022. 
33  Changes between reporting  periods  may  be  partially  explained  by 
improved knowledge or changes in assessment methodology. 

34  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.  Note: when  comparing  the 
figures shown for 2007-2012 and 2013-2018 these may also be affected 
by changes of methods or by better data availability. 
35 idem. 

Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture.  
The biodiversity and farm to fork strategies have set four 
important targets for 2030:  
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers);  
- bring back at least 10% of agricultural area under high-
diversity  landscape  features  and  increase  areas  under 
organic farming to at least 25%. 

Ireland, with an estimated 1.66 % of area under organic 
farming,  is  well  below  the  EU  average  of  9.07 %  (2020 
data, Eurostat). 

Figure  10:  Share  of  total  utilised  agricultural  area 
occupied by organic farming per Member State, 202036 

According  to  the  Commission  recommendations  for 
Ireland’s  CAP  strategic  plan37, 
Ireland’s  ammonia 
emissions from agriculture pose a significant risk. These 
make up 99% of the country’s total ammonia emissions  
–  the  highest  proportion  in  the  EU  –  and  have  been 
climbing  since  2011.  Almost  36%  of  the  total  reported 
emissions  of  nitrogen  oxides,  almost  40%  of  the  total 

Ireland  11 

reported  emissions  of  non-methane  volatile  organic 
compounds and 8% of the total fine particulate matter 
emissions in Ireland, come from agricultural sources. 

Ireland’s  soil  shows  generally  positive  characteristics 
There is no significant pressure from erosion by water, or 
from soil sealing. 

Just  3.6 %  of  Ireland’s  agricultural  area  lies  in  Natura 
2000 zones, compared with 11 % for the EU  However in 
any case, similar problems related to farmland habitats 
are  observed  more  generally,  even 
the 
monitoring of flora and fauna outside Natura 2000 zones 
needs to be improved.. 

though 

Key pressures on grasslands and heathlands include land 
use intensification – or, in some areas, abandonment  – 
as  well  as  inappropriate  mowing  practices  and  harmful 
burning of vegetation. Peatlands are under threat, which 
has a negative influence on biodiversity.  

Uptake of organic farming is very low in Ireland, covering 
1.6 % of utilised agricultural areas in 2020. 

Soil ecosystem 

soil 

new 

strategy, 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
adopted 
on 
The 
EU 
17 November 2021,  stresses  the 
importance  of  soil 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives as well as land-degradation neutrality by 2030.  
This entails:  
(i) preventing further soil degradation;  
(ii) making sustainable soil management the new normal;  
(iii) taking action for ecosystem restoration 

One factor  in the degradation  of soil ecosystems  is the 
area  of  soil  that  is  sealed  or  artificialised38.  In  Ireland 
(Figure  12)  the  land  taken  (i.e.  land  that  is  sealed  or 
artificialised)  per  year  in  2012-2018  can  be  seen  as  a 
measure  of  one  significant  pressure  on  nature  and 
biodiversity – land-use change. At the same time, land-
use  change  constitues  an  environmental  pressure  on 
people living in urbanised areas. 

Ireland ranks below the EU average with net land take of 
58.9 m2/km2 (EU-27 average: 83.8 m2/km2). 

Ireland  updated 

In  2018, 
land 
degradation  according  to  the  latestPRAIS3  reporting 
platform39  with  actions  intended  to  deal  with    the 
degradation identified. 

its  reporting  on 

36 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en (Eurostat, Area under organic farming, February 2022). 
37 EUR-Lex - 52020SC0377 - EN - EUR-Lex (europa.eu). 
38 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non-built-up  areas 

(including sealed area features, such as yards, farmyards, cemeteries, 
car  parking  areas  etc.  and  linear  features,  such  as  streets,  roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and  viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 
39 All Reports | Prais3 (unccd.int) 

Environmental Implementation Review 2022 – Ireland 

 
 
                                                                 
Ireland  12 

Figure  11:  Land  take  and  re-cultivation  in  the  EU-27 
(m2/km2), 2012-201840 

half  of  the  protected  forests  assessed  show  a  bad 
status44.  

Afforestation  in  Ireland  is  not  well  covered  by  the  EIA 
process. Very few, if any, EIAs have been carried out. 

Figure  12:    Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)45 

However, Ireland has not yet committed to setting Land 
degradation neutrality targets under the UN Convention 
to Combat Desertification (UNCCD)41.  

As  already  stated  in  the  2019  EIR,  soil  organic  matter 
plays an important role in the carbon cycle and in climate 
change.  Soils  are  the  second  largest  carbon  sink  in  the 
world after the oceans. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  ‘Fit  for  55’  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is to ensure healthy, diverse and resilient EU forests that 
contribute significantly to the strengthened biodiversity 
and climate ambitions.  
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050.  

Out  of  the  27 %  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favorable conservation status42. Bad conservation status 
increased from 27% to 31% in the EU compared to 2015.  

In  Ireland,  forests  cover  10.51 %  of  territory43  and  the 
situation  for  woodland  habitats  protected  under  the 
Habitats Directive is particularly worrying as more than 

(EUTR)46 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  According  to  the  EUTR,  EU  Member 
States’  competent  authorities  must  conduct  regular 
checks on operators and traders, and apply penalties for 
non-compliance.  With  the  amendment  of  Article  20  of 
the EUTR, reporting every 2 years has been changed to 
become annual reporting, and covers the calendar year 
as of 2019. 

In  the  period  from  March  2017  to  February  201947, 
Ireland  carried  out  8  checks  on  domestic  timber 
operators.  It  also  carried  out  42  checks  on  operators 
importing  timber.  Over  the  reporting  period, 
is 
estimated  that  Ireland  had  2 169  operators  placing 
imported timber types onto the internal market. 

it 

On 17 November 2021, a proposal for the Regulation on 
prohibiting  products  associated  with  deforestation  and 
forest degradation from being placed on the EU market 
and from being exported (Deforestation Regulation) was 
adopted.  adopted.  This  followeda  request  from  the 
Council in 2019 to table a legislative proposal to address 
this  problem  and  a  European  Parliament  resolution 
recommending the Commission to come forward with an 

40 European Environment Agency, Land take in Europe, December 2021. 
41  The LDN Target Setting Programme | UNCCD 
42  EEA, State of Nature in the EU 
43 EEA, Forest information system for Europe. 
44 COM SWD (2021) 652. 

45  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
46 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
47 COM/2020/629 final. 

Environmental Implementation Review 2022 – Ireland 

 
 
 
                                                                 
 
 
EU legal framework to halt and reverse EU-driven global 
deforestation.  

Figure  13:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Ireland, 2021 

Ireland  13 

This  new  Regulation  will  repeal  and  replace  the  EU 
Timber  Regulation,  as  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  leality  of 
timber. 

Invasive alien species (IAS) 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside changes in land and sea use, overexploitation, 
climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%.  

The  core  of  the  Regulation  on  Invasive  Alien  Species48 
(the IAS Regulation) is ‘the list of IAS of Union concern’.  

The total number of IAS of Union concern is currently 66, 
of which: 30 are animal species, 36 are plant species; 41 
are  primarily  terrestrial  species,  23  are  primarily 
freshwater species, 1 is a brackish-water species and 1 is 
a marine species. 

A 2021 report49 on the baseline distribution shows that 
of  the  66  species  on  the  Union  list,  22  have  been 
observed in the environment in Ireland. The spread can 
be checked in Figure 13. Of these species, 13 have been 
recorded but are not known to be established. 

An infringement case is ongoing  as Ireland failed to draw 
up  and  implement  one  single  action  plan  or  a  set  of 
action  plans  fulfilling  the  requirements  specified  in 
Article 13 of of the IAS Regulation by 13 July 2019 and to 
notify it/them to the Commission without delay. 

2022 priority actions 

  Address  serious  delays  and  deficiencies  in  Ireland’s 
marine Natura 2000 network through identification, 
selection and designation of sites under the Birds and 
Habitats Directives. 

  Complete the designation of terrestrial SACs and put 
in place the necessary conservation measures based 
on  clearly  defined  conservation  objectives,  so  that 
they  may  meet  their  objective  of  maintaining  or 
restoring species and habitats of community interest 
to  a  favourable  conservation  status  across  their 
natural range. 

  Take action  to end illegal turf cutting on raised-bBog 
SACs and to ensure that any turf cutting on blanket-
bog SACs is fully compatible with their protection in 
Natura 2000. 

  Take practical steps to address the serious decline of 
waders,  and  further  develop  the  conservation 
programme for the curlew, both in Natura 2000 sites 
and the wider countryside. 
the 
on 
recommendations  set  out  in  the  Irish  CAP  Strategic 
Plan.   

implementing 

  Step 

action 

up 

48 Regulation (EU) No 1143/2014 of the European Parliament and of the 
Council of 22 October 2014 on the prevention and management of the 
introduction and spread of invasive alien species. 
49  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 

concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170;  

Environmental Implementation Review 2022 – Ireland 

 
 
                                                                 
 
 
  Step  up  implementation  action  on  the  EU  Invasive 

Alien Species Regulation. 

Marine ecosystems 

Figure  14:  Level  of  adequacy  of  GES  determination  by 
Ireland  (ACS  region)  with  criteria  set  under  the 
Commission  GES  Decision  Decision  –  Article  9  (2018 
reporting exercise)53 

Ireland  14 

The  EU  Biodiversity  Strategy 
for  2030  aims  to 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems  and  to 
achieve good environmental status as well as eliminate 
or 
incidental  catches  of  protected, 
endangered, threatened and sensitive species to a level 
that allows species recovery and conservation[1]. 

reduce 

the 

The  Marine  Strategy  Framework  Directive  (MSFD)50 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine  waters,    and  cooperate  with  Member  States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

Among  other  obligations,  the  MSFD  requires  Member 
States  by  15 October 2018  to  draw  up  a  set  of  GES 
characteristics  for  each  descriptor  (Article  9),  and  to 
provide  an  initial  assessment  of  their  marine  waters 
(Article 8). The Commission then assesses whether this 
constitutes  an  appropriate  framework  to  meet  the 
requirements of the Directive. 

The Commission assessed Ireland’s 2018  determinations 
of  GES  for  each  of  the  MSFD’s  11  descriptors51  and 
determined  their  level  of  adequacy  in  relation  to  the 
Commission GES Decision52. A good or very good score in 
the Commission assessment  indicates that the national 
determinations  of  GES  are  well  aligned  with  the 
requirements  of  the  Commission  GES  Decision,  and 
national 
and 
provide 
environmental objectives to be achieved for their marine 
waters. 

quantitative 

qualitative 

Ireland  has  one  marine  sub-region:  ACS-NE  Atlantic: 
Celtic  Seas.  In  this  marine  sub-region,  7  out  of  11 
determinations  of  GES  were  assessed  as  good  or  very 
good.  The  national  determination  of  GES  by  Ireland  is 
coherent for 7 out of 11 descriptors. 

The  MSFD  also  requires  Member  States  to  assessthe 
current  environmental  status  of  their  marine  waters  in 
relation to the determination of GES. A good or very good 
indicates  that  the  Member  State  has  good 
score 
in 
capabilities  to  assess  their  marine  environment 
in  the 
accordance  with  the  requirements  set  out 
Commission GES Decision. 

[1]  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
50 Directive 2008/56/EC establishing a framework for community action 
in the field of marine environmental policy. 
51  Annex  I  of  Directive  2008/56/EC  establishing  a  framework  for 
community action in the field of marine environmental policy (Marine 
Strategy Framework Directive), OJ L 164, 25.6.2008, p. 19–40. 

52  This  assessment  was  made  in  relation  to  the  Commission  GES 
Decision, Commission Decision No 2017/848, pp. 43-74. 
53  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States in, January 2022. Note that only two 
sub-sections of descriptor D1 are displayed (D1-M Mammals and D1-B 
Birds). For  the analysis, these two sub-sections were considered as  a 
whole after averaging them. 

Environmental Implementation Review 2022 – Ireland 

 
 
                                                                 
 
 
Ireland  15 

levels  measured  above  (see  figures  14  and  15)  suggest 
that further actions are needed to achieve GES in those 
descriptors ranked as poor. 

Furthermore, in March 2022, the European Commission 
published a  Communication  with recommendations for 
Member States. The Commission assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine the good environmental status and the use of 
the  criteria  and  methodological  standards  according  to 
the Commission GES Decision. The above considerations 
form the basis for the 2022 priority actions. 

2022 priority actions 

 

in 

Implement  the  recommendations  made  by  the 
Commission57 
the  staff  working  document 
Communication58 
accompanying 
on 
the 
recommendations for each Member State and region 
on the 2018 updated reports for Articles 8, 9 and 10 
of the MSFD. 

  Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  (sub)  region  to  address 
predominant pressures. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States to better integrate biodiversity considerations into 
public and business decision making at all levels and to 
develop  natural  capital  accounting.  The  EU  needs  a 
better performing biodiversity observation network and 
the  condition  of 
reporting  on 
more  consistent 
ecosystems.  

An ecosystem assessment is an analysis of the pressures 
on  –  and  the  condition  of  –  terrestrial,  freshwater  and 
marine  ecosystems  and  their  services.  It  uses  spatially 
explicit  data  and  a  comparable  methodology  based  on 
European data about the functions of ecosystem assets 
and the ecosystem services they produce.  

Ecosystem  accounting  is  built  on  five  core  accounts 
(ecosystem  extent,  ecosystem  condition,  physical 
ecosystem  services,  monetary  ecosystem  services  and 
monetary  ecosystem  assets).  These  accounts  are 

development of Ireland’s marine protected area network can be found 
here. 
57 SWD(2022)1392. 

58 COM(2022)550. 

Figure15: Level of adequacy of national assessment of 
Ireland’s marine environment (ACS region) with 
criteria set under the Commission GES Decision – 
Article 8 (2018 reporting exercise)54 

A total of 9 descriptors out of 11 were scored as good or 
very  good. 
its  marine 
Ireland’s  assessment  of 
environment  is  coherent  with  requirements  set  under 
the Commission GES Decision for 9 out of 11 descriptors. 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of 
regional 
cooperation has improved since the MSFD was adopted, 
more cooperation is needed to attain regional alighment 
of the marine strategies, as required by the Directive. 

the  MSFD55,  while 

for  achieving  GES, 

The 2019 EIR noted that 77 % of Ireland’s measures were 
deemed  appropriate,  with  23 %    partially  appropriate, 
and  none  labelled  as  insufficient.  Nonetheless,  the 
Commission  suggested  that  Ireland  should:  (i)  set  the 
(ii) provide  more 
timelines 
information  about  measures,  (iii) decide  on  whether 
more  measures  that  directly  affect  the  pressures  on 
marine and coastal habitat are needed, and (iv) quantify 
the expected level of reduction in the pressure thanks to 
these  measures.  In  addition,  it  should  ensure  regional 
cooperation  with  Member  States  sharing  the  same 
marine  (sub)region  to  address  the  main  sources  of 
pressure, as well as ensure the different items under the 
MSFD  are  reported  by  the  set  deadline.  Ireland  made 
some  progress  on  the  above  actions56.  However,  the 

54  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Note that only two sub-
sections  of  descriptor  D1  are  displayed  (D1-M  Mammals  and  D1-B 
Birds). For  the analysis, these two sub-sections were considered as  a 
whole after averaging them. 
55 COM(2020)259. 
56 Ireland is currently drafting stand-alone legislation to enable marine 
protected areas to be identified, designated and managed in line with 
Ireland’s national and international commitments. Information on the 

Environmental Implementation Review 2022 – Ireland 

 
 
                                                                 
 
 
Ireland  16 

to 2020 (more info62). Irish Natural Capital Accounting for 
Sustainable  Environments  (INCASE)63  is  an  EPA-funded 
research project. It kicked off in March 2019 and will run 
until  2023.  INCASE  is  the  first  Irish  project  to  develop 
natural capital accounts for different sites in Ireland. 

Ireland has provided updated information and significant 
progress has been recorded  since  January 2016 (Figure 
16).  This  assessment  is  based  on  27  implementation 
questions and is updated every 6 months. 

Figure 16: ESMERALDA MAES Barometer, January 2016 
- March 202164 

2022 priority action 

  Continue supporting the mapping and assessment of 
ecosystems  and  their  services,  and  ecosystem 
accounting  development, 
through  appropriate 
indicators for integrating ecosystem extent, condition 
and  services  (including  some  monetary  values)  into 
national 
the 
development  of  national  business  and  biodiversity 
platforms, 
including  natural  capital  accounting 
systems to monitor and value the impact of business 
on biodiversity. 

supporting 

accounts; 

continue 

compiled  using  indicators  of  ecosystem  assets  and  the 
ecosystem services they produce.  

In  2015,  the  National  Parks  and  Wildlife  Service  of  the 
Department  of  Arts,  Heritage,  Regional,  Rural  and 
Gaeltacht Affairs  commissioned consultants to carry out 
a  short  pilot  to  map  and  assess  an  initial  suite  of 
prioritised  ecosystem  services.  The  project  developed 
indicators  for  mapping  potential  ecosystem 
spatial 
services,  based  on  available  national  data,  using 
methodologies developed in the UK and the EU. In the 
course  of  this  work,  it  reviewed  the  availability  and 
suitability of spatial data, identified data and knowledge 
gaps  to  inform  future  research  calls.  The  project  was 
completed in late 2016. More information is available on 
the NPWS website59 and the interactive mapping60. 

The Irish Forum on Natural Capital (IFNC), established in 
2015,  continues  to  grow  from  strength  to  strength, 
providing  a  range  of  seminars  and  training  workshops, 
aimed at developing and applying the agenda for natural 
capital in Ireland. 

The  national  biodiversity  action  plan  (2017-2021) 
included  a  number  of  activities  related  to  ecosystem 
services and accounting, as does the biodiversity climate 
change sectoral adaptation plan. 

The recently established Environment Statistics Accounts 
Division61 of Ireland’s Central Statistics Office have begun 
a  number  of  pilot  projects  in  collaboration  with  other 
government authorities  looking at forestry accounts and 
catchment level statistics. 

At  regional  level,  Dublin  and  adjacent  administrations 
participated in the EnRoute project (2017-2019).  In line 
with  the  project’s  overarching  objectives,  the  Irish 
project  aims to promote urban  ecosystem  services and 
develop green infrastructure. 

in  coordinating 
Ireland’s  EPA  has  a  statutory  role 
environmental research. Natural  capital and  ecosystem 
services  including  soils  and  biodiversity  were  themes 
included under its sustainability research pillar for 2014 

59  Ecosystems  Services,  Mapping  and  Assessment  |  National  Parks  & 
Wildlife Service (npws.ie). 
60  National  Ecosystem  and  Ecosystem  Services  Mapping  Pilot 
(arcgis.com) 
61 Home - CSO - Central Statistics Office. 

62 MAES (europa.eu). 
63 https://www.incaseproject.com/about. 
64 European Commission, Joint Research Centre, Publication Office, EU. 
Ecosystem assessment: summary for policymakers, page 80, May 2021. 

Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
 
 
 
 
Ireland  17 

3. Zero pollution 

the 

emission 

complied  with 

prior to review by the Commission, indicate that in 2020, 
reduction 
Ireland 
commitments for NOx, NMVOC, SO2 and PM2.5, and did not 
comply with the emission reduction commitment for NH3. 
Particularly problematic are rising emissions from cattle, a 
sector where Ireland has seen significant expanosion over 
recent years. 

Ireland  has  submitted  its  national  air  pollution  control 
programme (NAPCP) on 13 February 2021. 

Figure  17:  Emission  trends  of  main  pollutants/  GDP  in 
Ireland, 2005-201973 

Clean air 

its 

EU  clean  air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity should be further reduced with the long-term 
aim of not exceeding critical loads and levels. This requires 
strengthening  efforts  to  reach  full  compliance  with  EU 
clean-air  legislation  and  defining  strategic  targets  and 
actions for 2030 and beyond.  
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005.  

The EU has developed a comprehensive suite of air quality 
legislation,  which 
sets  health-based  air-  quality 
standards65  and  emission-reduction  commitments66  by 
Member State for a number of air pollutants. 

Air quality in Ireland is generally good with exceptions.The 
latest  available  annual  estimates  (for  2019)  from  the 
European  Environment  Agency  (EEA)67  point  to  about  1 
300 premature deaths (or 15 800 years of life lost (YLL)) 
attributable  to  fine  particulate  matter  concentrations68, 
50 (600 YLL) to ozone concentration69 and 30 (400 YLL) to 
nitrogen dioxide concentrations70 71. 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Ireland in recent years, while GDP growth 
continued (see graph). According to the latest projections 
as submitted under Article 10(2) of the National Emission 
  Directive  (NECD)72  Ireland 
Reduction  Commitments 
projects  to  reach  emission  reduction  commitments  for 
SO2, NOx and PM2.5 for 2020-2029 and for most pollutants 
from  2030  onwards.  However,  the  projections  do  not 
emission-reduction 
2020-2029 
demonstrate 
commitments 
organic 
non-methane 
compounds (NMVOC) and NH3, or the emission-reduction 
commitment  for  NMVOC  from  2030  onwards,  will  be 
reached.  The latest inventory data submitted by Ireland, 

that 
for 

volatile 

65 European Commission, 2016. Air Quality Standards.. 
66 European Commission, Reduction of National Emissions. 
67 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106. 
68  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to  particles with a diameter  of  10  (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
69 Low-level ozone is produced by photochemical action on pollution. 

70 NOx is emitted during fuel combustion e.g. from industrial facilities and 
the road transport sector. NOx is a group of gases comprising nitrogen 
monoxide (NO) and nitrogen dioxide (NO2). 
71  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive a 
sum. 
72 Directive 2016/2284/EU  
73 European Environment Agency. 

Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
Figure 18: PM2.5 and NOx emissions by sector in Ireland, 
201974 

Ireland  18 

2022 priority actions 

  As  part  of  the  NAPCP  take  actions  towards  reducing 
emissions from the main sources mentioned above. 
  Ensure  full  compliance  with  EU  air  quality  standards 
and  maintain  downward  emissions  trends  for  air 
pollutants to reduce adverse air pollution impacts on 
health and the economy with a view to reaching WHO 
guideline values in the future. 
the 

amended 
ratification  of 
Gothenburg Protocol under the UNECE Air Convention. 

  Accelerate 

the 

Industrial emissions 

The  main objectives of EU policy on industrial  emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  
To achieve this, the EU takes an integrated approach to 
the prevention and control of routine and accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive76 (IED). The Commission 
tabled a proposal in April 202277. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies.  

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry 
(2018)78. 

In Ireland, around 580 industrial installations are required 
to have a permit based on the IED. This is an increase of 
over  100  installations  since  2015,  mainly  in  the  waste 
management sector and in the intensive rearing of poultry 
or  pigs.  The  distribution  of  installations  is  shown  in  the 
Figure below. 

Industrial sectors in Ireland with the most IED installations 
in 2018 were intensive rearing of poultry and pigs (43%), 
followed  by  the  waste  management  sector,  including 
landfills  (17%),  food  and  drink  industries  (15%)  and  the 
chemicals sector (12%). 

In 2020, no exceedances above the limit values set by the 
Ambient Air Quality Directive  were registered75. 

Ireland  has  not  yet  ratified  the  amended  Gothenburg 
Protocol under the United Nations Economic Commission 
for Europe (UNECE) Air Convention. 

In the 2019 EIR, Ireland received four priority actions. The 
first was related to carrying out specific actions under the 
national  air  pollution  control  programme  (NAPCP).  Only 
limited progress has been made so far on this action, so it 
has  been  included  again.  The  other  three  addressed 
reductions  of  nitrogen  oxide,  ammonia  and  volatile 
organic compounds emission. On these actions also, only 
little  progress  has  been  made,  as  there  have  only  been 
small  reductions.  Ireland  also  received  a  general  priority 
action  in  2019  on  signing  and  ratifying  outstanding 
international agreements. 

74 idem. 
75 European Environment Agency, Eionet Central Data Repository 
76  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 

industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
77  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
78 EEA, European Industrial Emissions Portal. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
Figure  19:  Number  of  IED  industrial  installations  per 
sector in Ireland, 201879 

Figure  20: Emissions to air from IED sectors and rest of 
national total air emissions in Ireland, 201880 

Ireland  19 

The industrial sectors identified as contributing the largest 
burden to the environment for emissions to air were:   

 

 

 
 

 

 

the power sector for sulfur oxides (SOx), nitrogen 
oxides (NOx), arsenic (As), mercury (Hg) and lead 
(Pb); 
the  mineral  sector  for  chromium  (Cr),  mercury 
(Hg), nickel (Ni) and particulate matter (PM2.5); 
food and drink industries for NMVOCs; 
intensive rearing of poultry and pigs for ammonia 
(NH3); 
stationary 
combustion 
industries for nickel (Ni); 
‘other solvent use’ for cadmium (Cd), copper (Cu) 
and zinc (Zn); and 

in  manufacturing 

  waste management for dioxins. 

The breakdown is shown in Figure 20. 

The  environmental  burdens  for  industrial  emissions  to 
water,  excluding  emissions  from  wastewater  treatment, 
mainly  result  from  the  production  of  chemicals  for  total 
phosphorous and from the chemical and extractive sectors 
in case of heavy metals (based on E-PRTR data). 

The  EU  approach  taken  to  enforcement  under  the  IED 
creates strong rights for citizens to have access to relevant 
information and to participate in the permitting process. 
This empowers citizens, and NGOs, to ensure that permits 
are  appropriately  granted  and  the  conditions  of  these 
permits  are  complied  with.  As  part  of  environmental 
inspections, competent authorities undertake site visits to 
IED installations to take samples and to gather necessary 
information.  According  to  Article  23(4)  of  the  IED,  site 
visits must be carried out between once a year and once 
every  3  years,  depending  on  the  environmental  risks 
posed  by  the  installations.  In  2018,  Ireland  undertook 
1 113 site visits, most of which were to installations in the 
waste  management  sector  (32%),  followed  by  the  food 
and  drinks  industries  (28%),  the  chemicals  sector  (11%) 
and the intensive rearing of poultry or pigs (9%). 

79  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

80  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
 
Figure  21:  Number  of  inspections  in  IED  installations  in 
Ireland in 201881 

Ireland also has  some issues related to the transposition 
of the IED, which the  subject to an infringement case. 

Ireland  20 

2022 priority action 

  Continue  addressing  air  pollution  from  the  energy 

sector. 

Major industrial accidents prevention – SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;  
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;  
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.  
The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso-III Directive83). 

The  below  overview  of  industrial  plants  regulated  by 
Seveso-III Directive, (‘Seveso establishments’), is based on 
data  reported  to  the  eSPIRS  database  (2018)84  and 
Ireland’s  report  on  the  implementation  of  the  Seveso-III 
Directive for 2015-201885. 

In  Ireland,  of  the  93  Seveso  establishments,  44  are 
categorised as lower-tier establishments (LTEs) and 49 as 
upper-tier establishments (UTEs) – based on the quantity 
of hazardous substances likely to be present in them. The 
UTEs  are  subject  to  more  stringent  requirements.  The 
change 
is 
presented in Figure 22. 

in  the  number  of  Seveso  establishments 

Figure 22: Number of Seveso establishments in Ireland, 
2011, 2014 and 201886 

Many  Seveso  establishments  are  required  to  draw  up 
external emergency plans (EEPs). These EEPs are essential 
to allow proper preparation and effective implementation 
of the necessary actions to protect the environment and 
the population should a major industrial accident occur at 

The  development  of  best  available  techniques  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions82 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED. Since the last 
EIR, the Commission adopted BAT conclusions for Ireland 
for:  (i)  waste  incineration;  (ii)  the  food,  drink  and  milk 
industries;  and  (iii)  for  surface  treatment  using  organic 
solvents  including  the  preservation  of  wood  and  wood 
products with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution.  

to 

(ii) 

In  2019,  Ireland  received  priority  actions  to  review  (i) 
permits  in  order  to  comply  with  newly  adopted  BAT 
conclusions  and 
strengthen  control  and 
enforcement to ensure compliance with BAT conclusions. 
The Commission has followed up on these actions through 
Ireland’sreporting to the EU Registry. The  Commission is 
currently verifying with Ireland the reported information 
about the permits granted for each installation within the 
scope of the IED. Ireland also received the priority action 
to address air pollution from the power sector (use of higly 
polluting  peat  for  power  generation).  Action  has  been 
taken  on  this  front  with  Ireland  having  closed  two  of  its 
peat  burning  power  plants  (the  Shannonbridge  and 
Lanesboro plants) in 2020 with the last plant (Edenderry) 
due to stop burning peat in 2023. The BAT conclusions for 
large  combustion  plants  needed  to  be  addressed  by 
August 2021.  

81  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 
82 BAT reference documents | Eippcb (europa.eu). 
83  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 

84 European Commission, Seveso Plants Information Retrieval System. 
85 As provided for by Article 21(2) of the Seveso-III Directive 
86 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
Ireland  21 

them.  According  to  Ireland,  the  EEP  is  required  for  49 
UTEs. In 2018, 47 UTEs had an EEP and 45 of these EEPs 
have been tested over the last  3 years.  The summary  of 
EEPs in Ireland is shown in Figure 23. Drawing up EEPs is 
essential to allow for the necessary actions to be prepared 
properly  and  implemented  effectively  to  protect  the 
environment and the population should a major industrial 
accident ever happen. 

Figure 23: Situation regarding EEP in Ireland, 201887 

Ireland  has  some  issues  with  the  transposition  of  the 
Seveso III Directive which are subject to an infringement 
case. 

2022 priority actions 

  Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on EEPs. 

  Sign and ratify the TEIA convention 

Noise 

The  Environmental  Noise  Directive89  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.    A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people chronically disturbed by transport noise compared 
to 2017.  

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress90. 

In Ireland, based on a limited set of data91, environmental 
noise is estimated to cause at least around 50 premature 
ischaemic  heart  disease 
deaths  and  200  cases  of 
annually92.  Moreover,  some  30  000  people  suffer  from 
disturbed sleep.  In Irelthe proportion of  people exposed 
to noise reduced by 15 % between 2012 and 2017.  On the 
basis  of  the  latest  full  set  of  information  that  has  been 
analysed, the noise mapping of agglomerations, roads and 
railways is complete . 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status of water bodies as defined by the Water Framework 
Directive  will  ensure  that  EU  citizens  benefit  from  good 
quality and safe drinking and bathing water. It will further 
ensure that the nutrient cycle (nitrogen and phosphorus) 
is  managed  in  a  more  sustainable  and  resource-efficient 

on 

Air 

the  Environmental Noise Directive  2021: Methodology 

for 
under 
estimating missing data, ETC/ATNI Report No 2021/06, European Topic 
Centre 
Industrial 
Pollution; (iii) the methodology for health impact calculations, ETC/ACM, 
2018,  Implications  of  environmental noise on  health  and  wellbeing  in 
Europe, Eionet Report ETC/ACM No 2018/10, European Topic Centre on 
Air Pollution and Climate Change Mitigation. 

Transport, Noise and 

Pollution, 

The  following  types  of  information  are  permanently 
available for 100% of the Seveso establishments in Ireland: 
(i) information to the public referred to in Annex V of the 
Seveso-III  Directive,  especially  about  how  the  public 
concerned will be warned if there is a major accident; (ii) 
information  about  appropriate  behaviour  if  a  major 
accident occurs; and (iii) the date of the last site visit. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure 24. 

Figure 24: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Ireland, 2011, 2014 and 201888 

87 idem. 
88 idem. 
89 Directive 2002/49/EC 
90 WHO 2018, Environmental Noise Guidelines for the European Region 
91  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2017. 
92 These figures are an estimation by the European Environmental Agency 
based on  : (i) the  data  reported  by  Member  States  on noise exposure 
covered  by  Directive  2002/49/EC; (ii) ETC/ATNI,  2021, Noise indicators 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
 
 
                                                                 
Ireland  22 

while  only  6.9% achieved  a  good  chemical  status  (with 
91.9%  having  unknown status). For  groundwaters,  8.6% 
failed to achieve good chemical status while 0.2% failed to 
achieve good quantitative status. 

Ffigure  25  illustrates  the proportion  of  surface  water 
bodies in Ireland and other European countries that failed 
to achieve good ecological status. 

Figure 25:  Proportion  of  surface  water  bodies  (rivers, 
lakes, transitional waters and coastal waters) in less than 
good ecological status per rRiver basin district101 

The  following  figure  presents  the  percentage of surface 
water  bodies  in Ireland and  other  European  countries 
failing  to  achieve  good  chemical  status.   For  Ireland,  the 
percentage is 1.2% (with 91.9% having unknown status), if 
one  includes  water  bodies  failing  due  to  substances 
behaving as ubiquitous PBTs (uPBTs – substances that are 
persistent,  bio-accumulative  and  toxic).  Without  uPBTs, 
the  percentage  of  Irish  surface  water  bodies  failing  to 
achieve good chemical status remains less than 1% (with 
92% having unknown status). 

97 See the 6th Implementation Report of the WFD and FD. 
98  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Ireland, 2022. 
99 WISE Freshwater (europa.eu) 
100 River, lake, transitional, coastal, territorial. 
101 European Environment Agency, 2021. 

way. 

Water Framework Directive 

is 

(WFD)93 

the 
The  Water  Framework  Directive 
cornerstone of EU water policy in the 21st century94. The 
WFD  and  other  water-related  directives95  set  the 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status.  

for 

By March 2022, Member States had to report on the third 
round of river basin management plans (RBMPs).  Under 
the  WFD,  Member  States  must  draw  up  management 
plans for all river basins on their territory. Ireland has not 
yet  reported  on  it.  The  Commission  will  assess  the 
reported  status  of  river  basins  and  the  progress  made, 
checking how the findings identified in the Commission’s 
assessment  of  the  second  round  of  RBMPs96  have  been 
addressed. Ireland has yet to report on the third round of 
RBMPs. 

The  Commission  published  in  December  2021  the  6th 
Implementation  Report,  which  assesses  implementation 
of the WFD and the Floods Directive97. This report includes 
an  interim  assessment  of:  (i)  the  implementation  of  the 
programmes  of  measures;  and  (ii)  the  new  priority 
substances.  The  assessment  report  for  Ireland98showed 
that  it  was  difficult  to  assess  the  extent  to  which  the 
measures  included  in  the  Programme  of  Measures  are 
reaching the WFD’s objectives given the short time frame 
since the second RBMPs were adopted. A total of 25 key 
type measures have been drawn up to target 41 significant 
pressures  or  chemical  substances  across  Ireland’s  three 
river basin districts. 

The  Irish  administration  was  restructured  to  improve 
coordination  between  authorities  at  local,  regional  and 
levels  for  the  2nd  RBMP,  and  to  ensure 
national 
engagement  with  people  at  local  level  for  solutions  at 
catchment level. 

Based on the reporting and data obtained from the second 
round of RBMPs, published in 202099, in Ireland, 45.4% of 
all  surface  water  bodies100 achieved  a  good  ecological 
(with  24.7%  having  unknown  status 24.7%), 
status 

93 The Water Framework Directive (2000/60/EC). 
94 The EU Water Policy. 
95  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban Waste Water Treatment Directive (91/271/EEC), the new Drinking 
Water Directive (2020/2184/EC), the Nitrates Directive (91/676/EEC), the 
Marine  Strategy  Framework  Directive  (2008/56/EC)  and  the  Industrial 
Emissions Directive (2010/75/EU). 
96  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
                                                                 
 
Figure 26: Percentage  of  surface  water  bodies  not 
achieving good chemical status102 

Figure 27: Water abstraction per sector in Ireland104 

Ireland  23 

Under the IED framework, for industrial releases of heavy 
metals  like  Cd,  Hg,  Ni,  Pb,  Ireland  showed  a  significant 
decrease  over  the  last  decade  (41.8%).  ,However,  there 
was an increase  (40.5%) in total organic carbon (TOC) to 
water103. 

In  Ireland,  the  water  exploitation  index  plus  (WEI+)105  is 
2.98% (corresponding to year 2017), less than 20% that is 
generally considered to indicate water scarcity106. 

Figure 28: Water exploitation index plus (WEI+) inside 
the EU, 2017107 

Currently,  the  legislation  governing  water  abstraction  is 
being  reviewed  with  the  aim  of  introducing  a  water 
abstraction  licencing  regime  through  new  legislation. 
Ireland uses 
abstractions.  
However, small volume abstractions (less than 25 m3/day) 
are  not      registered. The  level  of  risk  due  to  abstraction 
pressures in Ireland is relatively low compared with other 
water management pressures. 

register for  water 

a 

in Ireland 

Total  water  abstracted  annually  (corresponding  to  2019 
from  surface  and  groundwater 
baseline) 
sources is 1340,94 hm3  (EEA,  2022).  The  percentage  for 
water abstraction per sector is (I) 3.04% for agriculture, (ii) 
62.89% for public water supply, (iii) 0.14% for electricity, 
for 
(iv)  4.94%  for  manufacturing  and  (v)  27.13% 
manufacturing  cooling,  and  (vi)  1.86%  for  mining  and 
quarrying, as shown in Figure 27 below. 

On  pollution,  Ireland showed  a significant  decrease  over 
the  last  decade (41.8%) in  industrial releases of  heavy 
metals  like  Cd,  Hg,  Ni,  Pb.  However,  there  was   an 
increase (40.5%) in Total Organic Carbon, (TOC) to water 
(EEA, 2021) .  

Floods Directive 

As  mentioned  above,  the  Commission  published 
in 
December  2021  the  6th  Implementation  Report,  which 
assesses  the  implementation  of  both  the  WFD  and  the 
Floods Directive. The report includes a review and update 
of the preliminary flood-risk assessments drawn up by all 
Member States during the second cycle (2016-2021). 

The  assessment  report108  showed  that 
Ireland  has 
improved  its  procedures  for  collecting  data  on  floods, 

102 European Environment Agency, December 2019. 
103 European Environment Agency, June 2021. 
104  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
105 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how much water is abstracted and how much water is returned after use 
to the environment. 

106 By May 2022, the EEA will develop a seasonal WEI+ at river basin and 
NUTS2 level, which will provide a more complete picture of water stress 
and water scarcity for each Member State. 
107 European Environment Agency, Water exploitation Index Plus, 2022. 
108  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification of Areas of Potential Significant Flood Risk under the Floods 
Directive : Member State : Ireland, 2022. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
 
 
including information on the impacts of flooding. A clear 
methodology  is  in  place  for  the  designating  areas  of 
potential  significant  flood  risk  (APSFRs).  Climate  change 
has been taken into account in the flood risk assessment.  
A cross-border coordination group has been established to 
coordinate  the  implementation  of  the  Floods  Directive 
between Ireland and Northern Ireland, which can be seen 
as  a  model  for  good  practice  as  it  builds  on  well-
the 
established  working 
assessment 
identified  that  the  collection  of  further 
information about how floods affect the environment and 
cultural heritage needs to be improved. 

relationships.  However, 

Ireland has recently 
reported the second generation 
of flood risk management plans (FRMPs) under the Floods 
Directive.  The European  Commission will  now assess 
progress  since  the  adoption  of  the  first  Flood  Risk 
Management Plans. It will then publish a new report, as it 
did in 2019. 

Drinking Water Directive 

On the Drinking Water Directive109, there has been no new 
assessment of the quality of Drinking Water isince the  EIR 
2019.  The  Commission  has  an  open 
infringement 
procedure    (INFR(2017)4007)  against  Ireland  which  is  at 
the  Referral  to  Court  stage  (Art  258  TFEU).  This  raises 
concerns  about  Ireland’s  failure  to  comply  with  the 
parametric  value  for  trihalomethanes  in  a  number  of 
systems  that  supply  drinking  water  across  the  whole 
country.  

The  recast  Directive110 entered  into  force  on  12  January 
2021.  Member  States  have  until  12  January  2023  to 
transpose  it  into  their  national  legal  system.  Ireland  will 
have to comply with these reviewed quality standards. 

Bathing Water Directive 

On the Bathing Water Directive,  Figure 17 shows that  in 
2020, out of the 148 Irish bathing waters, 75%) % were of 
excellent  quality111.  Detailed  information  on  the  Irish 
bathing  waters  is  available  from  a  national  portal112  and 
via  an 
interactive  map  viewer  on  the  European 
Environment Agency website113. 

109 OJ L 330, 5.12.1998, p. 32–54. 
110 OJ L 435, 23.12.2020, p. 1–62. 
111  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu). 
112 https://www.beaches.ie/  
113 EEA, State of bathing waters in 2020 — European Environment Agency 
(europa.eu). 

Ireland  24 

Figure 29:   Bathing water quality in Europe in the 2020 
season114 

Figure 30: Ireland, Bathing water quality, 2017-2020115 

Nitrates Directive 

The latest Commission Report on the Implementation of 
the  Nitrates  Directive116,  referring  to  the  period  2016-
2019117,  warns  that  nitrates  are  still  causing  harmful 
pollution  in  EU  water.  Excessive  nitrates  in  water  are 
harmful  to  both  human  health  and  ecosystems,  causing 
oxygen  depletion  and  eutrophication.  Where  national 
authorities and farmers have cleaned up waters, it has had 

114 European Environment Agency, Bathing Water Quality in 2020, 2022. 
115  European  Environment  Agency,  European  Bathing  Water  Quality 
in 2017, 2018, 2019, 2020. 
116  Implementation of the Nitrates Directive in the EU. 
117 Last Implementation Report 2016-2019. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
                                                                 
 
 
 
impact  on  drinking  water  supply  and 
a  positive 
biodiversity,  and  on  the  sectors  such  as  fisheries  and 
tourism  that  depend  on  them.  Nevertheless,  excessive 
fertilisation remains a problem in many parts of the EU. 

Livestock pressure in Ireland is above the EU average. The 
surplus  of  nitrogen  is  about  the  EU  average,  while  the 
surplus of phosphorus is among the highest in the EU. The 
network of monitoring stations is sufficiently developed. 
The  groundwater  quality  is  generally  good,  while  the 
number of monitoring stations have an increasing trend. 
Surface  waters also have low nitrate concentrations and 
the number of waters that are eutrophic remains limited. 
On  11  March  2022,  Ireland  published  its  fifth  Nitrates 
Action Programme118. 

Urban Waste Water Treatment Directive  

Over  the  years,  Ireland  has    encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment Directive (UWWTD).  

Overall, 44% of the urban waste water in Ireland is treated 
according  to  the  requirements  of  the  UWWTD119.  This 
is below the  EU  average  of 76%  in  2018.  Further  efforts 
are  needed  to  provide  biological  treatment  to  an 
additional  50.5%  and  biological  treatment  with  nitrogen 
and/or phosphorus removal to 75.1%. 

Figure  31:  The  proportion  of  urban  waste  water  that 
meets  all  requirements  of  the  UWWTD  (collection, 
biological treatment, biological treatment with nitrogen 
and/or phosphorus removal) in compliant urban areas of 
the UWWTD (‘compliance rate’), 2018120 

Despite  improved  compliance  throughout  the  years,  the 
incomplete  implementation  of  the  UWWTD  has  led  to 
several  rulings  of  the  Court  of  Justice  of  the  European 
Union  against  Ireland.  Currently,  the  Commission  is 
following up on a judgment of the Court in case C-427/17 
(rendered under Article 258 TFEU which covers numerous 
agglomerations  which  are  in  breach  of  the  Directive, 

Ireland  25 

including  the  two  biggest  agglomerations  of  Dublin  and 
Cork). 

The 2019 EIR for Ireland included two priority actions on 
water  management.  Considering  that  the  progress  has 
been limited, the following actions are suggested. 

2022 priority actions 

  New physical modifications of water bodies should be 
assessed in line with Article 4(7) of the WFD. In these 
assessments  alternative  options  and  adequate 
mitigation measures have to be considered. 

  Maintain efforts to reduce diffuse nutrients pollution 

and to address hydromorphological pressures. 

  Maintain  efforts  to  improve  monitoring,  in  particular 
of hydromorphological conditions, priority substances 
and groundwater quantity. 

  Urgently  ensure  an  appropriate  control  over  water 
abstraction  and  hydromorphological  changes 
in 
compliance with the Water Framework Directive. 
  Efforts should be made to improve coordination in the 
implementation of water, marine and nature policies. 
  Review  its  action  programme  regarding  the  high 
nutrients phosphorus surplus and continue to follow-
up  on  the  monitoring  of  hotspot  areas  that  show 
increasing nitrate concentrations. 

  Complete implementation of the Urban Waste Water 
Treatment Directive for all agglomerations, by building 
up the necessary infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  -  'Towards  a  Toxic-Free  Environment'121 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU's zero-pollution 
ambition  –  a  key  commitment  of  the  European  Green 
Deal. 

legislation122 provides  a  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market.  

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
the  Regulation  on 
(the  REACH  Regulation)  and 

118 In response to water quality trends, new measures have been included the new 
Regulations as either additions or enhancements of the Good Agricultural Practice 
Regulations 2017 (S.I. No. 65 of 2017), as amended, 
119 Ireland (europa.eu). 

120 European Commission, WISE Freshwater, 2021. 
121 COM(2020) 667 final. 
122  REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
Ireland  26 

o  Both  proactive  and  reactive  inspection;  on-site 
inspections  focus  on  registration  obligations, 
compliance with SDS, Annex XIV and Annex XVII 
requirements.  

  The DAFM: 

o  Risk-based approach. 

  The EPA:  

o 

Strategy  forms  part  of  the  Agency’s  overall 
Internal Market Surveillance strategy; 

o  Risk-based approach. 

. In addition to prosecution for offences, the responsible 
authority may also, where necessary, order the provisional 
seizure of assets and documents. 

The  following  is  the  breakdown  of  the  number  of  staff 
members allocated to REACH and CLP enforcement127 :  

 

 

 

The Health and Safety Authority (HSA): 20.7 full 
time  equivalent  (FTE)  inspectors  to  enforce  all 
chemicals  regulations  and  other  environmental 
regulations, 5.95 FTEs to enforce REACH, and 6.2 
FTEs to enforce CLP; 
The  HHSA also created a  new chemicals market 
surveillance unit of 5 FTEs in preparation for the 
impact of Brexit;  
The  DAFM:  28  inspectors  whose  duties  include 
REACH  and  CLP.  In  addition,  there  is  the  EPA 
Chemicals  Team.  Accordingly,  more  than  533 
REACH  and  CLP  controls  carried  out  in  the 
reporting  period.   Almost  all  the  REACH  controls 
done  are  proactive  (inspections),  compared  with 
reactive/non-routine controls (i.e. investigations in 
response to complaints, accidents and referrals). 

The high percentage of non-compliance cases out of the 
total number controls should be underlined128. 

Labelling  and  Packaging 

(the  CLP 
Classification, 
Regulation). In December 2020, the Commission assessed 
the  Member  States’  reports  on  the  implementation  and 
enforcement  of  these  Regulations123,  in  line  with  Article 
117(1)  of  the  REACH  Regulation  and  Article  46(2)  of  the 
CLP  Regulation.  According  to  the  latest  available  data, 
national enforcement structures have not changed much. 
However, it is apparent from this report that there are still 
many disparities in the implementation of the REACH and 
CLP Regulations, notably in the area of law enforcement. 
Recorded compliance levels in Member States seem to be 
quite stable over time, but with a slight worsening trend, 
which  is  likely  due  to:  (i)  enforcement  authorities  being 
detecting 
more 
non-compliant 
effective 
products/companies;  and 
(ii)  more  non-compliant 
products being put on the EU market.  

in 

In August 2021, the Commission published a  measurable 
assessment  of  the  enforcement124  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 
CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement. 

Responsibility  for  checking  compliance  with  REACH  in 
Irelandlies with the following authorities125: 

  Department  of  Agriculture  Food  and  the  Marine 

(DAFM) (also for CLP) 

  Health and Safety Authority (also for CLP) 
  Environmental Protection Agency (EPA) 

Ireland  has  devised  and  fully  implemented  both  REACH 
and CLP enforcement strategies126. Their content consists 
of: 

  The Health and Safety Authority:  

o  The Authority's REACH enforcement strategy is a 
its  Authority’s  overall  strategy 

subset  of 
statement;  

o  The annual enforcement work programme;  
o  Priorities  for  enforcement  activities  based  on 
broad  analysis  of  the  risk  of  non-compliance. 
Priorities  given  to  chemicals  of  highest  risk 
(substances  that  are  carcinogenic,  mutagenic  or 
toxic for reproduction CMRs and sensitisers) and 
to  actors  with  the  greatest  responsibility  in  the 
supply chain;  

o  The  work  programme  indicates  the  number  of 
inspections,  including  audits,  to  be  carried  out 
annually and the number of product assessments 
to be undertaken; 

123 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu). 
124  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 
125 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 69. 

126 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76. 
127 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 74. 
128  Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 87-
88. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
                                                                 
 
Figure 32: Percentage % of non-compliance cases out of 
the total number of REACH and CLP controls during 2019 
per Member State and compared to the EU average129 

Ireland  27 

2022 priority action 

  Upgrade 

the 

for 
administrative 
implementation and enforcement in order to follow a 
zero-tolerance approach to non-compliance  

capacities 

. 

129 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
 
                                                                 
 
 
 
 
 
Ireland  28 

4. Climate action

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing greenhouse gas (GHG) emissions by 55% by 2030 
compared  to  1990.  The  law  also  limits  the  contribution 
that  carbon  removals  can  make  towards  emission 
reductions in 2030 to ensure a sufficient mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
nationally determined contributions (NDC) to the UNFCCC 
in December 2020.  
The EU is working across all sectors and policies to cut GHG 
emissions  and  make  the  transition  to  a  climate-neutral 
and  sustainable  economy,  as  well  as  addressing  the 
unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from transport, the maritime sector and fluorinated gases 
(F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010130  and  sets  binding  GHG  emission 
standards for different vehicle categories131.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From 2021, emissions and removals of GHGs from LULUCF 
have been included in the EU emission-reduction efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required to report on their national adaptation policies132, 
as  the  EU  Climate  Law  recognises  adaptation  as  a  key 
component  of  the  long-term  global  response  to  climate 
change. Member States will be required to adopt national 
strategies, and the EU will regularly assess progress as part 
of its overall governance on climate action. The updated 
EU adaptation strategy, published in February 2021, sets 
out how the EU can adapt to the unavoidable impacts of 
climate change and become climate resilient by 2050. 

Key national climate policies and strategies 

Ireland has an integrated National Energy and Climate Plan 
(NECP)  for  2021-2030  that  includes  investments  and 
reforms  in  line  with  its  target  under  the  Effort  Sharing 
Regulation.  This  work  builds  upon  long-term  energy  and 
climate plans. The adoption of the first Climate Action Plan 
in 2019 represented a breakthrough in climate policy, and 
Ireland  adopted  legislation  in  2021  that  sets  a  national 
climate  neutrality  target  by  2050  with  an  intermediate 
objective  of  reducing  total  emissions  by  51%  by  2030 
compared to 2018 levels. National legislation establishes a 

strong  framework  for  climate  policy,  which  includes  the 
drawing  up  of  economy-wide  and  sector-specific  5-year 
carbon budgets on a rolling 15-year basis. It also sets out 
an  obligation  to  revise  annually  the  Climate  Action  Plan  
and makes government Departments responsible for the 
delivery of their carbon budgets and mitigation targets. 

In its national Recovery and Resilience Plan (RRP), Ireland 
allocates  42%  of  it  to  climate  objectives  and  outlines 
crucial reforms and investments to further the transition 
to  a  more  sustainable,  low-carbon  and  climate-resilient 
economy. 

Ireland's  first  statutory  National  Adaptation  Framework 
(NAF)  was  published  in  2018.  It  sets  out  the  national 
strategy  to  reduce  the  country’s  vulnerability  to  the 
negative effects of climate change and to take advantage 
of the positive impacts. The NAF was developed under the 
Climate Action and Low Carbon Development Act 2015. A 
statutory review of the NAF will be completed in 2022. 

GHG  emissions  in  2020  were  6%  above  1990  levels  and 
emissions  per  capita  are  among  the  highest  in  the  EU, 
having decreased little since 1990. 

Figure  33:  Total  greenhouse  gas  emissions 
international aviation) in Ireland 1990-2020 

(incl. 

Effort sharing  

For emissions not covered by the  EU’s emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets under the Effort  Sharing legislation133.. Under EU 
legislation, Ireland has a target of reducing GHG emissions 
in  the  non-ETS  sectors  (buildings,  road  and  domestic 
transport,  agriculture,  waste  and  small 
maritime 

130  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements for fuels used in road transport in the EU to protect human 
health and the environment, and to make road travel across the EU safer. 

131 Directive 98/70/EC. 
132 Article 29 of Regulation (EU) 2018/1999. 
133 Regulation (EU) 2018/842. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
                                                                 
 
Ireland  29 

industries) by 20% by 2020 and by 30% by 2030, compared 
to 2005 levels. In 2020, the country’s ESR emissions were 
well above its 2020 target. -In its NECP, Ireland intends to 
achieve similar reductions than its current ESR target for 
2030 of 30%. 

Figure 34: Emissions and targets under the Effort Sharing 
Decision/ Effort Sharing Regulation in Ireland, 2020 and 
2030 as percentage change from 2005 

advanced  biofuels,  incentivizing  the  development  and 
deployment  of  renewable  fuels  of  non-biological  origin 
and 
refining 
processes. 

reducing  upstream  emissions  before 

Road transport in 2019 in Ireland represented 18% of the 
country’s  total  GHG  emissions.  Emissions  of  GHG  from 
road have decreased by 7% compared to 2005. 

Figure 36: Greenhouse gas emissions by sector in 
Ireland134  – historical emissions 1990-2020, projections 
2021-2030135 

Figure 35: Emissions, annual emission allocations (AEAs) 
and  accumulated  surplus/  deficit  of  AEAs  under  the 
Effort Sharing Decision in Ireland, 2013-2020 

Key sectoral developments 

In  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Ireland  decreased  by  3,4%  between  2010  and  2019. 
Ireland needs to act swiftly to meet the current EU-wide 
target of 6% by 2020 compared to 2010. There are several 
types of action that Member States can take in this regard, 
for  example  further  expanding  the  use  of  electricity  in 
road transport, supporting the use of biofuels, in particular 

134  The  sectors  in  the  figure  correspond  to  the  following  IPCC  sectors: 
Energy supply: 1A1, 1B and 1C. Energy use in manufacturing industries: 
1A2.  Industrial  processes  and  product  use:  2.  Transport:  1A3.  Other 
energy  use:  1A4,  1A5  and  6.  Agriculture:  3.  Waste:  5.  International 
aviation: 1.D.1.a. 

To  further  reduce  emissions  from  buildings,  more 
measures to support investments in energy efficiency and 
to  promote  the  uptake  of  heating  systems  based  on 
renewable energies are needed in existing buildings. The 
national retrofit plan136 identifies steps to further reduce 
GHG emissions from residential buildings  

Emissions  from  agriculture  have  increased.  The  share  of 
non-CO2  emissions  in  total  GHG  emissions  in  Ireland  is 
atypically large in the EU context, mainly due to emissions 
of biogenic methane. Mitigating emissions from the cattle 
and dairy farming will clearly be a challenge, but it will also 
offer  opportunities  for  agriculture  and  the  agro-food 
industry to transition to sustainable modes of production. 

The  Land  Use,  Land  Use  Change  and  Forestry  (LULUCF) 
sector is currently a net source of emissions. Projections 
indicate  a  slight  decrease  of  LULUCF  emissions  by  2030. 
Reported  quantities  under  the  Kyoto  Protocol  for  the 
LULUCF  sector  in  Ireland  show  net  emissions  of,  on 
average,  2.1  Mt  CO2-eq  between  2013  and  2019. 
Therefore, Ireland represents -0.6% of the annual average 
sink of 344.9 Mt CO2-eq of the EU-27. Accounting for the 

135 European Environmental Agency, Total GHG trends and projections. 

136 215252_a53faf62-c2ec-44d3-9cff-b61715a6d79f.pdf 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
 
                                                                 
 
same period shows net credits of, on average, -3.9 Mt CO2-
eq,  which  corresponds  to  3.4%  of  the  EU-27  accounted 
sink  of  -115.0  Mt  CO2eq.  Reported  net  emissions  and 
accounted  net  credits  show  fluctuations  with  no  clear 
trend.  Ireland  is  one  of  three  EU  Member  States  with 
average net emissions and one of six EU Member States 
that  show  net  emissions  for  at  least  one  year.  Ireland 
elected to report and account for cropland management 
as  one  of  six  EU  Member  States  and  for  grazing  land 
management as one of five EU Member States. 

Figure 37: Reported and accounted emissions and 
removals from LULUCF in Ireland137 

Ireland  30 

Use of revenues from the auctioning of EU ETS 
allowances 

from 

revenues 

the  auctioning  of  emission 
Total 
allowances under the EU ETS in 2012-2021 were EUR 765 
million.  In  Ireland,  the  revenues  are  not  earmarked  for 
specific purposes, amounts spent are equivalent to 100% 
of these revenues and are allocated to emission reduction 
activities. 

2022 priority actions 

Increase the uptake of renewables. 

 
  Decarbonise transport. 
 

Improve  energy  efficiency  in  existing  residential  and 
commercial buildings. 

  Upgrade  the  current  power 

infrastructure  and 
strengthen  its  ability  to  cope  with  high  shares  of 
variable generation.  

  Reduce  non-CO2  emissions 
enabling  the  agro-food 
sustainable modes of production. 

in  agriculture  while 
industry  to  transition  to 

  Exercise continuous vigilance over the sustainable use 
of biomass and its actual impacts on carbon sinks and 
biodiversity due to the increasing share of biomass in 
the energy sector. 

137  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory note 

on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol’.   

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
 
                                                                 
 
 
 
Ireland  31 

Part II: Enabling framework: Implementation tools

5. Financing

Environmental investment needs in the 
European Union 

13-28  billion  a  year,    depending  on  levels  of  circularity 
implemented.  The  annual  biodiversity  financing  gap  is 
estimated at around EUR  20 billion. 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to  close  the  financing  gaps.  Post-2020,  environmental 
measures  will  also  be  supported  by  the  EU’s  COVID-19 
Recovery  Fund  (via  the  RRF)  and  the  ‘do  no  significant 
harm’  principle  which  runs  across  the  EU  budget.  The 
(Glasgow, 
renewed  commitments  made  at  COP26 
October-November 2021) and the Biodiversity Convention 
(April-May 2022)138 will also be reflected in the EU budget. 

Overall environmental investment gaps (EU27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed and what is forecast to be invested if no additional 
action  is  taken)  for  climate,  energy  and  transport  were 
estimated in 2021 at EUR 390 billion per year (EU-27)139, 
with  a further EUR 130 billion  a  year  to deliver the EU’s 
core  environmental  objectives140.  The  costs  of  climate-
change  adaptation  can  also  be  significant,  and  are 
estimated to reach a total of EUR 35-62 billion (narrower 
scope)  or  EUR  158-518  billion  (wider  scope)  per  year141. 
implementation 
Those 
objectives to 2020 and to 2030 (except for climate-change 
adaptation, the costs of which are expected to last over a 
longer time horizon).  

investment  needs  reflect  the 

A  preliminary  update  of 
the  EU’s  environmental 
investment  gap  is  provided  in  Table  1142.  Almost  40%  of 
the environmental investment gap relate to dealing with 
pollution, accounting for nearly two-thirds of the total gap 
if combined with water management. The investment gap 
in circular economy and waste is estimated between EUR 

138  The  Convention  on  Biological  Diversity  (cbd.int);  Post-2020  Global 
Biodiversity Framework | IUCN. 
139 SWD (2021) 621, accompanying proposal COM (2021) 557 to amend 
the REDII Directive (EU) 2018/2001. 
140 SWD (2020) 98 final/2.  
141  SWD(2018)292 
Regulation. 
142  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  Source:  DG  ENV  “Study  supporting  EU  green  investment 
needs  analysis”  (ongoing,  2021-2023)  and  DG  ENV  internal  analysis” 
Environmental  investment  needs  and  financing  in  the  EU’s  green 
transition” July 2020. 
143 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-2023) and DG Environment 

Impact  assessment  accompanying 

the  LIFE 

Table  1:  Estimated  breakdown  of 
environmental 
objective, 2021-2030 (per annum)143 

the  EU27’s 
investment  gaps,  by  environmental 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems144 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in Ireland 

Ireland's  top  priority  for  environmental  investment  is 
biodiversity,  followed  by  water,  pollution  management 
and  waste.  The  following  environmental  investment 
needs have been identified by sector.  

Pollution prevention & control 

The EU’s first Clean Air Outlook145 estimated that the total 
air  pollution  control  costs  for  Ireland  to  reach  the  NECD 
emission  reduction  requirements  (ERRs)146  by  2030 

internal analysis ”Environmental Investment needs and financing in the 
EU’s green transition“, July 2020. 
144  To  meet  the  needs  of  the  2030  Biodiversity  Strategy  (Natura 2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for  nature  (COM/2020/380  final)  while  to  fully  cover  the  strategy 
(including restoration) EUR 30-35 billion may be needed, indicating a gap 
of EUR 10-20 billion a year compared to current baseline expenditure. 
145 International Institute for Applied Systems Analysis (IIASA), Progress 
towards the achievement of the EU's air quality and emissions objectives, 
2018.  
146 Covering the reductions of and the emission ceilings for 5 atmospheric 
pollutants, SOx, NOx, PM2.5, NH3 and VOC by 2030, compared to 2005. 
Source:  Progress  towards  the  achievement  of  the  EU’s  air  quality  and 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
 
                                                                 
 
 
Ireland  32 

amount  to  EUR  915  million  per  year,  including  EUR  581 
million for capital investment (assuming the achievement 
the 2030 climate and energy targets). 

The second EU’s Clean Air Outlook147 suggests that, if all 
relevant  legislation adopted  up to 2018  (including all air 
pollution and the 2030 climate and energy targets  set in 
2018) delivered its full benefits and if Member States also 
implemented  the  measures  announced  in  their  NAPCPs, 
the  EU would 
largely  achieve  the  reductions  of  air 
pollutant  emissions  that  correspond  to  the  obligations 
under the NEC Directive for 2030, except for 15 Member 
States for ammonia (NH3), including Ireland.  

Water management  

According  to  the  OECD  study  ‘Financing  a  Water  Secure 
Future’  (2022)148,  nutrient  enrichment  from  agriculture 
and  untreated  sewage  (i.e.  inappropriate  treatment  or 
sewer overflow when rainfall occurs) is the main pressure 
on  water  quality  in  Ireland.  Nitrate  concentration  in 
groundwater is an issue, particularly in the southeast and 
south part of Ireland. It is also estimated that Ireland will 
need to invest an additional cumulative EUR 1 479 million 
by 2030 over baselines for drinking water and sanitation – 
corresponding to around EUR 148 million investment need 
(capital  expenditure)  per  annum,  almost  90%  of  that 
relating to wastewater149. An attempt to introduce water 
charges  for  water  supply  and  sanitation  services  was 
repelled in the spring 2017. As a consequence, domestic 
water users in Ireland do not pay a bill for normal water 
use150.  [Information  from  the  6th  Water  Framework 
Directive  and  Floods  Directive  Implementation  Report151 
and the financial - economic study152 accompanying the 6th 
Implementation Report to be taken into account].  

Waste & circular economy 

According  to  a  Commission’s  study153  to  meet  the 
recycling targets for municipal waste and packaging waste, 
Ireland  still  needs  to   invest  an  additional  EUR  371 
millions (around 53 million per annum) between 2021 and 
2027 in  collection,  recycling  reprocessors,  biowaste 
treatment,  waste  sorting  facilities  and  waste  registry 

digitalisation - which already includes additional costs of 
replacting bio-waste treatment faciliites (a total of EUR 9.3 
million  in  2021-2027).  This  does  not  include  investment 
necessary  for  other  key  waste  streams  (plastics,  textile, 
furniture)  or  to  reach  higher  circularity  and  waste 
prevention across the economy. 

Biodiversity & ecosystems 

The  recently  submitted  priority  action  framework  (PAF) 
for Ireland shows that nature protection costs (including 
Natura  2000)  in  2021-27  are  EUR  1138  million.  This 
represents an annual cost of about EUR 162.6 million, of 
which EUR 23.5 million are one-off costs154.  More efforts 
may be necessary to cover the increased ambitions of the 
EU Biodiversity Strategy 2030 and any relevant financing 
gaps on protection and restoration. 

EU environmental funding 2014-2020 

The multiannual financial framework (MFF) for 2014-2020 
allocated almost  EUR 960 billion (in  commitments, 2011 
prices)155  for  the  EU  to  spend  over  this  period.  The 
commitment 
in  this  2014-2020  MMF  to  the  green 
transition included a 20% climate spending target. It also 
included  funding  opportunities  for  the  environment,  in 
particular, under the European Structural and Investment 
(ESI)  Funds156.  The  2014-2020  MFF  budget  was 
subsequently topped up with over EUR 50 billion (current 
prices)  from  the  REACT-EU  programme  (for  cohesion-
policy action against COVID-19)157.  

Ireland received EUR 4.3 billion from the ESI Funds over 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR 373.0 million with further EUR 38.3 million identified 
as  indirect  environmental  investment  value,  totalling  to 
EUR  411.3  million.  Figure  39  shows  an  overview  of 
(planned) individual ESI Funds earmarked for Ireland (EU 
amounts, without national amounts). 

emissions objectives, IIASA 2018. (page 29). Requirements are based on 
Directive (EU) 2016/2284. 
147 COM(2021) 3 Final and Report Annex.   
148  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, 2020.  
149 OECD, Ireland- Country fact sheet- Financing Water Supply, Sanitation 
and Flood Protection. 
150 OECD, Financing a Water Secure Future, 2022. 
151  WFD  and  FD  Implementation  Reports  -  Environment  -  European 
Commission (europa.eu) 
152  European  Commission,  Directorate-General 
for  Environment, 
Economic data related to the implementation of the WFD and the FD and 
the  financing  of  measures  :  final  report,  Publications  Office,  2021, 
https://data.europa.eu/doi/10.2779/163850  

153 European Commision, Study on investment needs in the waste sector 
and on the financing of municipal waste management in Member States, 
2019.  
154  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving synergies with EU funding instruments report to the European 
Commission, 2021.  
155 Council Regulation (EU, Euratom) No 1311/2013. 
156  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI), the European Agricultural Fund for Rural Development (EAFRD) and 
the European Maritime and Fisheries Fund (EMFF). 
157 Regulation (EU) 2020/2221. 

Environmental Implementation Review 2022– Ireland 

 
  
                                                                 
 
Figure 38: ESI Funds allocated to Ireland, including 
environmental investments, 2014-2020158 

Ireland  33 

environment  protection  &  resource 
efficiency 
Direct environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

0.2 
0.2 

411.3 
373.0 
38.3 

Funding for the environment from the ESI Funds has been 
also  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States,  such  as,  the  LIFE 
loans  from  the 
programme,  the  Horizon  2020,  or 
European  Investment  Bank  (EIB),  that  add  up  to  an 
estimated  total  of  EUR  782  million  of  EU  environmental 
financing for Ireland in 2014-2020. 

is  entirely  dedicated 

The  LIFE  programme160 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best  practice  actions  for  green 
solutions to be deployed. In the 2014-2020 period, Ireland 
has received EU support for nine LIFE projects (for nature 
and  environment)  with  EUR  43.0  million  from  the  LIFE 
programme (out of 1 028 EU27 LIFE projects with the total 
EU contribution of EUR 1.74 billion)161. 

It 

is  about  2.3%  of 

In 2014-2020, the Horizon 2020 allocated about EUR 27.5 
million for Ireland for the environment (in particular, for 
climate  action,  circular  economy  and  nature  and 
resources)  which 
Ireland’s  total 
allocation162.  From  the  European  Fund  for  Strategic 
Investments (EFSI), Ireland received EUR 28.5 million for 
direct  environmental 
its  total 
allocation  (EUR  811.9).163  From  the  EIB,  Ireland  received 
EUR  300.0  million  for  direct  environmental  investments, 
specifically, for water and sewerage) out of the total EIB 
loans  for  Ireland  (EUR  6.1  billion)164.  The  country  ranks 
number 14 in size in total EIB lending. 

investments  out  of 

Table 2:  Direct  and indirect Environmental investments 
under the ESI Funds in Ireland, 2014-2020159 

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
land rehabilitation 
Indirect environmental investments 
energy efficiency 
sustainable transport 

Under EAFRD/rural development 
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 

Allocations  
for the environment  
(EUR million) 

50.8 
18.0 
18.0 
32.8 
31.6 
1.2 

267.7 
262.3 
1.4 
260.9 
5.4 
0.6 
4.8 

92.8 
92.6 
92.6 

Policy 

Funds 

(COWI, 

2017), Regulation 

158  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
(EU) No 215/2014. Cut-off date for data: December 2021. Environmental 
investments  here  are  captured  via  the  combined  use of  intervention 
fields 
No 
under 
1303/2013 and Regulation (EU) 2021/1060  allowing for a more precise 
identification and valuation of relevant environmental investments. N.B. 
Indirect  environmental  investments  are  valued  using  the  Annex  I 
(EU)  2021/1060 (as 
environmental  coefficients  of  the Regulation 
opposed to full value). 
159 European Commission, DG Environment - Data analysis. The values of 
environmental investments identified here in the specific environmental 

the Regulation 

coefficients 

(EU) 

and 

the 

may 

from 

differ 

tracking 

values 
areas 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis here covered the full range of 
ESI Funds. See also previous footnote.  
160 European Commission, LIFE Programme. 
161 LIFE (europa.eu). 
162 Source: https://sc5.easme-web.eu/. 
163  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
164 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 

Environmental Implementation Review 2022– Ireland 

 
 
  
                                                                 
 
 
In 2020, the EIB provided EUR 24.2 billion to fight climate 
change, 37% of its total financing and EUR 1.8 billion (3% 
of its financing) for the environment165 166. 

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls upon 
EUR  1  trillion  green  investments  (public  and  private)  by 
2030.  The  multiannual  financial  framework  (MFF)  2021-
2027 and the NextGenerationEU will mobilise EUR 2.018 
trillion  (in  current  prices)  to  support  the  COVID-19 
recovery  and  the  EU's  long-term  priorities,  including 
environmental  protection.167  Following  the  EU  Green 
Deal’s168  ‘do  no  harm’  pledge  and  the  Interinstitutional 
Agreement  on  the  2021-2027  MFF169,  30%  of  the  EU 
budget will support climate efforts and 7.5% (as of 2024) 
and 10% (as of 2026) biodiversity that requires increased 
programming  of  financial  resources  for  biodiversity, 
specifically under the 2021-2027 Cohesion policy and the 
2023-2027 CAP to reach those targets. 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)170,  strengthens  non-financial  reporting 
requirements, facilitates green bond issuance (by the EU 
green  bond  standard171).  Reinforced  by  the  Renewed 
Sustainable  Finance  Strategy  (2020)172  it  will  increase 
investment flows to climate and environment. In support 
of  financing  climate  adaptation,  the  new  strategy  on 
adaptation to climate change173 can facilitate to close the 
insurance  protection  gap  from  non-insured  climate-
related events174. The EIB will align 50% of its lending with 
climate  and  environment  by  2025175  with  an  EUR  250 
billion contribution to the Green Deal Investment Plan by 
2027. 

Table  3  makes  an  overview  of  the  EU  funds  earmarked 
specifically to Ireland for the 2021-2027 period. 

that 

finance 

several  programs 

165  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU, the successor of EFSI, Pillar II and III of the Just 
Transition  Mechanism.  The  EIB  Group  stands  as  a  key  implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
166 EIB 2021 Activity Report.. 
167  European  Commission,  2021-2027 
NextGenerationEU. 
168 COM/2019/640 final. 
169 Interinstitutional Agreement, OJ L 433I. 
170 

https://ec.europa.eu/info/business-economy-euro/banking-and-

long-term  EU  budget  & 

finance/sustainable-finance/eu-taxonomy-sustainable-activities_en   
171 EU Green Bond Standard - 2021/0191 (COD). 
172 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy.  
173 COM(2021) 82 final. 
174  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 

Ireland  34 

Table  3:  Key  EU  funds  allocated  to  Ireland  (current 
prices), 2021-2027 

Instrument 

Country funding allocation 
(million EUR) 

Cohesion policy 

Total: 1 197.7176 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027179 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

Recovery 
Resilience 
(RRF)  

and 
Facility 

2021 – 2026182  

395.8  

508.3 

293.6177 

84.6178 

1 558.2180 

142.4181 

989.0 (grants)183 

In Ireland, the programming for the majority of EU funds 
(cohesion  policy  funds,  EAFRD  and  EMFAF)  is  ongoing.  
However,  the  negotiations  have  been  concluded  under 
the RRF. 

Ireland’s  recovery  and  resilience  plan    consists  of  16 
investment measures and 9 reforms across 3 components. 
supported  by EUR  989  million in 
They  will  be 
grants.   41.8% of 
support climate 
investments and reforms (see Figure 40). In terms of green 
transition,  the  plan  reflects 
its  climate  pledge  by 
enshrining the objective to achieve climate neutrality by 

the  plan  will 

EIOPA (the Association for European Insurance and Occupational Pension 
Authorities)  dashboard  on 
insurance  protection  gap  for  natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
175 EIB Climate Bank Roadmap 2021-2025, November 2020. 
176  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
177 Interreg initial allocations per MS including ETC transnational and ETC 
cross-border co-operation.  
178  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
180 Regulation (EU) 2021/2115, Annex XI.  
179 European Commission, CAP strategic plans.  
181 Regulation (EU) 2021/1139, Annex V. 
182  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
183 Council Implementing Decision, FIN 636. 

Environmental Implementation Review 2022– Ireland 

 
 
                                                                 
 
 
 
2050 into legislation and disincentivising the use of fossil 
fuels, as well as  encouraging  a  shift  from private cars to 
rail transport by investing in the commuter rail network in 
Cork  (EUR  164  million).  It  will  also  assist  households, 
businesses  and  the  public  sector  to  implement  energy 
efficiency investments and green technology solutions to 
reduce carbon emissions (EUR 155 million) and restoration 
and  rehabilitation  of  wetlands  to  change  land  use  from 
peat extraction to carbon sequestration184. 

Figure 39: Climate expenditure in RRP, 2021-2026185 

Under NextGenerationEU, the Commission will issue up to 
EUR 250 billion of EU green bonds (one third of all bonds 
issued  under  NextGenerationEU)  until  2026  that  will 
comply  with  the  general  spirit  of  the  ‘do  no  significant 
harm’  principle.  However,  this  EUR  250  billion  in  green 
bonds  will  not  be  subject  to  the  currently  developed 
delegated  acts  related  to  the  EU  Taxonomy  and  will  not 
fully  align  with  the  proposed  EU  standards  for  green 
bonds. 

In addition to EU funds earmarked specifically for Ireland 
in  the  2021-2027  period,  there  are  also 
funding 
programmes  that  can  be  accessed  at  the  EU  level  and 
which are open to all member states on competitive basis. 
These include, among others, the LIFE programme186 (EUR 
5.4  billion),  Horizon  Europe (EUR  95.5  billion)187,  the 
Connecting  Europe  Facility  (EUR  33.7  billion)188 or  the 
funds  to  be  mobilised  via  the  InvestEU189.  They  will  also 
support  the  green  transition,  including  research  and 
innovation  activities 
for  environmental  protection 
(Horizon  Europe)190, clean  transport  and  energy  (the 

184 European Commission, Ireland recovery and resilience plan.  
185 European Commision 
186 European Commission, LIFE Programme. 
187 European Commission, Multiannual Financial Framework 2021-2027 
(in commitments) - Current prices. 
188 Regulation (EU) 2021/1153. 
189  The  InvestEU Fund  is foreseen  to  mobilise  over  EUR  372  billion  of 
investment  through  an  EU  budget  guarantee  of  EUR  26.2  billion  to 
back the 
investment  of  financial  partners  such  as  the  European 
Investment Bank (EIB) Group and others. 
190 European Commission, Horizon Europe. 

Ireland  35 

Connecting 
infrastructure (InvestEU)192. 

Europe 

Facility)191 or 

sustainable 

National environmental protection 
expenditure 

Total  national  environmental  protection  expenditure 
(including all relevant current and capital expenditure)193 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  the  common  GDP  being  quite  stable  over  time. 
While  absolute  expenditure  is  concentrated  in  a  few 
countries,  as  a  share  of  GDP,  most  countries  spend 
between 1-2%, with Ireland below that range (0.6%). 

Of  the  above  total,  capital  expenditure  (Capex)  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR  56.3  billion  in  2018,  lowering  to  EUR  54.5  billion  in 
2020,  representing  around  0.4%  of  GDP.  Most  Member 
States  invested  0.2-0.5%  of  their  GDP  in  environmental 
protection,  Ireland  dedicated  0.2%.  During  2014-2020, 
this totalled to around EUR 376 billion of environmental 
investment  in  the  EU-27,  and  to  EUR  3.91  billion  for 
Ireland. 

Figure 40: Direct and indirect environmental protection 
investments  in  the  EU-27  (EUR  million  and  %  of  GDP), 
2018194 

level, 

including  final  consumption, 

191 European Commission, Connecting Europe Facility. 
192 European Union, InvestEU.   
193  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 
194 Eurostat, Environmental Protection Expenditure Account, 2021. 

Environmental Implementation Review 2022– Ireland 

 
 
 
                                                                 
 
 
from 

specialist  producers 

By  institutional  sector,  most  of  Ireland’s  environmental 
protection  investments  (83%)  came  from  the  general 
government,  6% 
(of 
environmental protection services, e.g. waste and water 
companies) and  11% from  the  industry (business) sector 
that normally pursues environmental activities as ancillary 
to  their  main    activities.    At  EU  level,  37%  comes  from 
governments,  33%  from  specialist  producers  and  30% 
from industry (business). 

Figure  41:  EU-27  Member  States'  environmental 
protection  investments  (Capex)  by  institutional  sectors 
(Total economy = 100%), 2018195 

protection 

Breakdown  of  investment  by  environmental  topic  is 
partially available, at the level of institutional sectors only 
(rather than at economy level), due to different reporting 
patterns196. At Ireland’s general government level, 72% of 
to 
environmental 
wastewater, 7% to waste management and 17% was non-
classified. In case of the country’s specialist producers, the 
dominant, almost exclusive, area was waste management 
(97%).  The  business  sector  was  concerned  with  several 
areas: waste management (34%), protection of air (31%), 
wastewater (17%), water- and soil protection (14%). 

investments  went 

The total annual European green bond issuance197 in 2020 
was USD 156 billion (EUR 137 billion198), growing from USD 

195 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
196 Data reporting is different for  the 3 institutional  sectors, leading to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data across all environmental areas (CEPA 1-9), while this is less the case 
for  general  government  and  industry  that  often  report  (the  non-
obligatory) data in merged categories only (with difficulty to split) or not 
at all.  
197  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green “use of proceeds” or asset-linked bonds. The very first 

Ireland  36 

117 billion (EUR 105 billion) in 2019, also including some 
non-EU  European  countries.  By  EU-27  Member  States 
only, the 2020 annual green bond issuance was EUR 124 
billion.  83%  of  the  green  bonds  issued  by  European 
countries served energy, buildings or transport objectives 
between 2014-2020, 8% supported water and waste, with 
further 6% supporting land use – with links to ecosystem 
conservation & restoration, based on the  Climate Bonds 
Taxonomy being broadly similar to the EU Taxonomy199. Of 
this 2020 annual EU green bond issuance, Ireland’s had a 
EUR 1.23 billion amount. 

Figure 42: Annual EU green bond issuance in 2020 (EUR 
billion)200 

Green budget tools 

Green taxation & tax reform 

Ireland  revenue  from  environmentally-related  taxes 
remains  around  the  lowest  in  2020  with  EUR  4520.2 
million  in  absolute  amount,  as  shown  in  the  Figure  43. 
Compared to GDP it was also low (1.21%), a bit more than 
half  of  the  EU-average.  Within  this,  energy  taxation 
represents  the  highest  share  with  61.5%  in  2020,  while 
transport  tax  represents  38.2%  and  pollution/resources 
tax  accounts  for  0.2%.  The  share  of  transport  taxes  are 
double that of the EU-average (18.9%), while pollution and 
resource taxes are almost non-existing. 

green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
198 At Eurostat’s annual average EUR/USD exchange rates. 
199 
information 
Bonds 
https://www.climatebonds.net/standard/taxonomy 
200 Climate Bonds Initiative, 2022. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 

Climate 

on 

Environmental Implementation Review 2022– Ireland 

 
 
 
                                                                 
 
Ireland  37 

objectives. In many cases they also go against incentives 
for  green  investments  not  contributing  to  levelling  the 
playing  field.  Fossil  fuel  subsidies  vary  around  EUR  55 
billion  in  the  EU  since  2015.  They  rose  by  4%  between 
2015 and 2019, however some countries, such as Latvia, 
Lithuania  Sweden,  Greece  or 
Ireland,  managed  to 
decrease subsidies for fossil fuels. In the EU, subsidies on 
petroleum  products,  in  sectors  such  as  transport  and 
agriculture,  kept  on  growing  over  this  period,  whereas 
subsidies on coal and lignite decreased, largely owing to 
diminishing role of solid fuels in electricity generation.  

As a share of GDP, fossil fuel subsidies ranged from 1.2% 
in Hungary to less than 0.1% in Malta in 2019 (being 0.4% 
on  EU  average).  In  2019  For  Ireland,  the  total  fossil  fuel 
subsidies amounted to EUR 1.5 billion, representing 0.44 
% of the GDP. Ireland allocates more than the EU average 
on  fossil-fuel  subsidies  —  and  higher  than  renewable-
energy subsidies207. 

In  2020,  the  EU27’s  total  amount  of  fossil  fuel  subsidies 
decreased  to  EUR  52  billion  (due  to  falling  consumption 
trends  amid  the  COVID-19-related  restrictions)  which, 
without  Member  State  actions,  are  likely  to  rebound  as 
from  2020208.  Further 
economic  activity  picks  up 
information regarding environmental harmful subsidies in 
Ireland is shown below. 

Figure  44:  Trends  in  natural  gas,  petroleum  products, 
electricy and coal subsidies in Ireland209 

Figure 43: Environmental taxes in the EU27, 2020201 

simultaneously 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition. Tax reforms can contribute to this by sending 
the right price signals and incentives to economic players. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil-fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations202. The Green Deal promotes the ‘polluter 
pays  principle’  (PPP)203,  which  stipulates  that  polluters 
should bear the cost of measures to prevent, control and 
remedy pollution. The polluter-pay principle is facilitated 
the  European  Commission’s  Technical  Support 
by 
Instrument (TSI) project on greening taxes204. According to 
a  Commission’s  study  on  Green  taxation  and  other 
economic  instruments (2021) Ireland could introduce an 
intensive agriculture tax and a waste water pollution taxes 
to  further  address  particular  areas  of  environmental 
concern205. 

account  of 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms206. 

Fossil  fuel  subsidies  are  costly  for  public  budgets  and 
adversely  impact  the  achievement  of  the  Green  Deal 

% 
GDP 

 2013  2014 

  2015  2016 

2017 

2018 

2019 

202
0 

201 Eurostat, Environmental taxes accounts (env_eta). 
202 COM (2019/640 final), p.17.  
203 Enshrined in Article  191(2)  of  the  Treaty  on the  Functioning  of  the 
European Union: ‘Union policy on the environment (…) shall be based on 
the precautionary principle and on the principles that preventive action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay’.  
204  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice  

205  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021.  
206  European  Commission,  Study  on  assessing  th  environmental  fiscal 
reform potential for the EU 28, 2016.   
207  European  Court  of  Auditors,  Energy  taxation,  carbon  pricing  and 
energy subsidies, 2022.  
208  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex.  
209 OECD, Fossil Fuel Subsidy Tracker. 

Environmental Implementation Review 2022– Ireland 

 
 
                                                                 
 
0,07 

0,06 

  0,05 

0,04 

0,04 

0,04 

 0,03 

0,03 

Overall financing compared to the needs 

Ireland  38 

Electri
city 

Natur
al gas 

Petrol
eum 
produ
cts 

0,05 

0,07 

  0,03 

0,03 

0,04 

0,05 

0,03 

0,03 

0,82 

0,81 

0,63 

0,61 

0,59 

0,61 

0,58 

0,43 

Coal 

0,07 

0,08 

0,06 

0,05 

0,05 

0,03 

0,02 

0,02 

Fossil fuel subsidies remain significant in Ireland and have 
in  fact  been  rising  over  the  past  decade.  In  2018,  peat 
production  and  consumption  remained  subsidised  and 
other subsidies and exceptions existed for oil, natural gas 
and coal. Diesel is still taxed at a lower rate. The different 
tax  treatment  of  diesel  and  gasoline  for  road  use  is 
beginning to be addressed with a 1% vehicle registration 
tax  surcharge  for  diesel  engine  passenger  vehicles 
registered  in  Ireland  from  1  January  2019.  In  addition, 
fiscal measures are being extended in 2019 to support the 
purchase of electric, hybrid and plug-in hybrid vehicles. 

Green budgeting practices 

Green  budgeting210  encompasses  various  climate  and 
environmental  tagging  and  tracking  practices  in  budgets 
and some EU Member states already use green budgeting 
elements211.  Green  budgeting  helps  identify  and  track 
green  expenditure  and  green  revenues  to 
increase 
implications  of 
transparency  on  the  environmental 
improving  policy  coherence  and 
budgetary  policies, 
supporting  green  policies 
(including  climate  and 
environmental objectives)212. 

EU climate proofing and sustainability proofing guidance 
have  also  been  developed,  as  tools  to  assess  project 
eligibility  and  compliance  with  environmental  legislation 
and  criteria.213  The  EU  Commission  established  a  green 
launched  a 
budgeting  reference 
technical support flagship (TSI) on green budgeting in 2021 
to  assist  Member  States 
in  developing  or  further 
developing national green budgeting frameworks to reap 
the  benefits  for  policy  coherence  and  for  the  green 
transition.  Ireland  participates  in  the  EU  Commission’s 
green budgeting TSI started in 2021. 

framework214  and 

The  overall  environmental  financing  for  investments  is 
estimated to have reached  0.6-0.7% of GDP in the 2014-
2020  period  in  the  European  Union,  taking  into  account 
major EU funds and national financing. This ranged from  
0.3% (Ireland) to  1.91% (Bulgaria), linked to the level of 
individual  environmental  challenges  in  Member  States. 
The  overall  EU  environmental  investment  needs  in  the 
2021-2027 period are estimated to  range from 0.9-1.5% 
of the projected GDP (2021-2027), suggesting a potential 
environmental financing gap of 0.6-0.8% of GDP (EU level), 
unchanged financing patterns assumed215. 

Figure 45: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% 
of GDP)216 

Ireland’s overall environmental financing for investments 
is  estimated  to  have  been    0.3%  of  GDP  in  2014-2020, 
mostly  coming  from  national  sources.  The  country’s 
environmental investment needs in 2021-2027 are found 
to be over  0.48% of GDP (including needs with country-
level  breakdown  available),  suggesting  a  potential 
environmental financing gap of at least  0.18% of the GDP, 
that is likely to be higher when also accounting for need 

210 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
211 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. and OECD, Public Governance Directorate, Climate Change 
and  Long-term  Fiscal  Sustainability,  Working  Paper,  February  2021. 
Climate Change and Long-term Fiscal Sustainability (oecd.org) 
212  European  Commission,  European  Commission  Green  Budgeting 
Reference Framework.  
213 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 

214 European Commission, Green Budgeting Reference Framework, based 
on  the  review  of  the  OECD  Paris  Collaborative  on  Green  Budgeting 
initiative, 2017. 
215 Source: DG Environment data analysis. EU financing sources covered: 
ESI Funds (ERDF, CF, ESF, YEI, EAFRD, EMFF), Horizon 2020, LIFE, EFSI (EU 
amount),  EIB  loans.  National  financing:  total  national  environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset. Cut-off date for data: end 2021. N.B. The total financing may be 
higher,  in  particular  through  further  indirect  investments,  requiring 
further analysis in the future.   
216 Eurostat, ESI Funds Open Data, 2021. 

Environmental Implementation Review 2022– Ireland 

 
 
 
                                                                 
 
 
 
Ireland  39 

currently  estimated  at  EU-level  only 
protection, circularity, biodiversity strategy etc.).  

(e.g.  water 

implementation  gaps,  bringing  together  all  relevant 
administrative levels. 

In  the  2019  EIR,  Ireland  had  no  priority  actions  for 
environmental  financing.  However,  there  is  room  for 
improvement in the next years. 

2022 priority actions  

  To  devise  an  environmental  financing  strategy  to 
maximise  opportunities  for  closing  environmental 

  To ensure an increased level of financing, and further 
exploit  opportunities  in  private  financing,  for  the 
environment to cover the investment needs identified 
across  the  environmental  objectives  and  to  close 
investment gaps. 

Environmental Implementation Review 2022– Ireland 

 
 
 
Ireland  40 

6. Environmental governance

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  
(i) access to information;  
(ii) public participation in decision making; 
(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively217.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows citizens and NGOs to use national courts to protect 
the  environment218.  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’)219. 

 Environmental information 

Ireland’s  implementation  of  the  INSPIRE  Directive  has 
been  bad.  Its  performance  has  been  reviewed  based  on 
the country's 2021 country fiche220. Ireland’s progress on 
data identification and documentation has been slow , and 
the  accessibility  of  spatial  data  sets  is  bad.  More  efforts 
are needed to: 

  make the data more widely accessible,  and  
  prioritise  environmental  datasets  in  implementation, 
identified  as  high-value  spatial 
environmental 

implementing 

especially  those 
datasets 
legislation221. 

for 

217  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive(Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation.  
218 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
219  This EIR  focuses  on the  means implemented by  Member  States  to 
guarantee  rights  of  access  to  justice,  legal  standing  and  to  overcome 
other major barriers to bringing cases on nature and air pollution. 

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016-2020222 

2016 

2020 

Legend 

■  Implementation  of 
this  provision  is  well 
advanced  or  (nearly) 
completed. 
Outstanding 
issues 
are minor and can  be 
easily. 
addressed 
Percentage: >89% 

■  Implementation  of 
this  provision  has 
started  and  made 
some  or  substantial 
progress but is still not 
close  to  be  complete. 
Percentage: 31–89%. 

■  Implementation  of 
this provision is falling 
significantly  behind. 
Serious  efforts  are 
to  close 
necessary 
implementation  gap. 
Percentage: <31%. 

Effective coordination and data 
sharing 

Ensure effective 
coordination  

■  ■ 

sharing 

Data 
without 
obstacle  

■  ■ 

INSPIRE performance indicators 

i. Conformity of 
metadata 

■  ■ 

ii. Conformity of 
data 
spatial 
sets223 

iii.  Accessibility 
of  spatial  data 
through 
sets 
view 
and 
download 
services 

iv.  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

Public participation 

The EIA Portal is the central portal for information on EIA 
projects. It contains all the relevant information related to 
an application for development consent. However, it does 
not  provide  a  means  to  engage  with  a  particular 
application but rather a conduit to the relevant competent 
authority website for further information and methods to 
make  submissions/observations.  There  is  currently  no 
strategic  environmental  assessment 
(SEA)  portal. 
However, developing an SEA Portal is part of the Ireland’s 
current SEA Action Plan. 

220 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/IE. 
221 European Commission, List of high value spatial data sets. 
222 INSPIRE knowledge base. 
223 The deadlines for implementation of the spatial data interoperability 
were  in  2016  still  in  the  future:  23/11/2017  for  Annex  I  data  and 
21/10/2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
majority  of  the  countries  provide  as-is-data  sets  in  addition  to  the 
INSPIRE harmonised data sets. 

Environmental Implementation Review 2022– Ireland 

 
 
 
 
 
                                                                 
 
in  decision  making  processes 

There  is  a  lack  of  data  available  on  the  level  of  public 
participation 
including 
authorisations linked to EIA Directive 2011/92/EU and SEA 
Directive  2001/42/EC.  The  public  participation  in  the 
environmental  impact  assessment  procedures  is  difficult 
to  assess 
in  the  absence  of  public  participation 
monitoring.  Nonetheless,  progress  has  been  made  in 
developing key standalone resources for SEA224.  

There is a lack of evidence of public participation, which 
makes it difficult to confirm whether public participation 
in EIA procedures has declined. 

late 

Ireland  was  very 

in  transposing  Directive 
As 
2014/52/EU  on  environmental  impact  assessments,  the 
Commission has not  yet  assessed the correctness of the 
transposition  of  the 
legislation  adopted  by  Ireland. 
Concerns have also been raised  through an infringement 
procedure initiated by the Commission about the failure 
to carry out  environmental impact assessments for peat 
extraction activities despite the large number of projects 
that fall into this category in Ireland. 

Access to justice 

standing 

to  have 

in 
For  environmental  NGOs 
environmental cases, they have to meet some conditions 
as regards their legal status and operation, e.g. their aims 
must be related to promoting the environment and they 
must  have  pursued  that  objective  over  the  previous  12 
months.  Both  primary  and  secondary  legislation  can  be 
challenged  by  way  of  judicial  review.  Where  primary 
legislation is challenged, the reliefs will be declaratory in 
nature.  A  party  only  has  locus  standi  (i.e.  the  right  or 
capacity  to  bring  an  action  or  to  appear  in  a  court)  to 
challenge the constitutionality of a  statutory provision if 
they prove an interest. 

As the Department responsible nationally for the Aarhus 
Convention, the Department of the Environment, Climate 
and  Communications  provides  general  information  on 
access to justice225. The Citizens’ Information website also 
provides general information on the Aarhus Convention226 
and  specific  information  about  planning/environmental 
judicial review227. There is some information on access to 
justice, usually in the official language of the country only, 

live  public  consultations  on  statutory 

224 The mentioned resources on SEA are: (i) EPA SEA WebGIS Search and 
Reporting  tool,  (ii)  EPA  Inventory  of  Spatial  Information  Sources  ;  (iii) 
EPA-funded SEA Environmental Sensitivity Mapping (ESM) webtool, (iv) 
the   Interactive  map of  the Office  of  the  Planning  Regulator displaying 
details  of 
land  use  plans 
(https://gis.epa.ie/EPAMaps/SEA);  (v)  management  of  an SEA  activity 
statistics  portal;  and  (vi)  the  Public  Participation  and  Performance 
Criteria  in  Strategic  Environmental  Assessment:  The  Way  Forward  to 
Advancing Practice (SEAWAY), co-founded by EPA and the Office of the 
Planning Regulator entitled. This is a 24-month project that will help to 
inform the development of an SEA portal. 

Ireland  41 

maintained  by  the  government,  and  it  needs  to  be 
searched for. 

The costs of environmental court procedures represent a 
very  significant  obstacle  to  accessing  justice,  even  fora 
high-income  individual  or  organisation.  Own  costs  in 
complex cases are not  unknown to exceed EUR 500 000 
Euros228.  The  Commission  remains  concerned  about  the 
high  costs  of  environmental  litigation  and  the  lack  of 
clarity as to what costs environmental litigants are likely 
to face from the outset. The Commission has opened an 
infringement  procedure  on  this  matter  and  adressed  a 
letter of formal notice to Ireland under Article 258 of the 
Treaty  on  the  Functioning  of  the  European  Union.For 
several years, Ireland has promised to clarify the rules on 
costs for access to justice through a consolidating Aarhus 
Bill,  but  this  has  not  uet  materialized.  Instead,  recent 
national  court  judgments  have  created  confusion  about 
what costs fall under the cost protection rule. Moreover, 
proposals in a Housing Bill appear to aim to further restrict 
access  to  environmental  justice.  Since  2019,  access  to 
environmental  justice  has  not  improved.  Furthermore, 
environmental  NGOs  have  been  openly  criticised  by 
government ministers for bringing cases which challenge 
certain  developments  and  some 
lawyers  acting  for 
environmental  litigants  have  faced  strategic  lawsuits 
against public participation (SLAPP) suits. 

In the 2019 EIR, priority actions were addressed to Ireland 
on  access  to  justice,  in  particular,  to  remove  the  cost 
barriers and to better inform the public about their rights. 
There  has  been  no  progress  on  either  of  these  two 
aspects. 

2022 priority actions 

 

Improve access to spatial data and services by forming 
stronger 
INSPIRE 
linkages  between  the  Federal 
website  and  regional  portals,  identify  and  document 
all  spatial  datasets  required  for 
implementating 
environmental law229, and at least make the data and 
documentation  accessible  “as  is”  to  other  public 
authorities and the public through the digital services 
as set out in the INSPIRE Directive. 

  Make  significant  improvements  to  ensure  that  high 
costs  and  the  lack  of  clarity  about  those  costs  in 
advance of any legal action do not hinder the effective 

225https://www.gov.ie/en/publication/b3b1a-aarhus-
convention/#access-to-justice. 
226https://www.citizensinformation.ie/en/environment/environment_a
nd_the_law/aarhus_convention.html. 
227https://www.citizensinformation.ie/en/environment/buildings_and_
structures/judicial_review_in_planning_and_environmental_matters.ht
ml. 
228 Case C-470/16 – North East Pylons. 
229 European Commission, INSPIRE. 

 Environmental Implementation Review 2022 – Ireland 

 
                                                                 
Ireland  42 

access  to  justice  in  environmental  matters.  It  is 
recommended that Ireland draw up an action plan to 
address problems with prohibitively expensive judicial 
procedures in the environmental field. 

  Better inform the public about their access to justice 
rights, in particular by referring to a range of resources, 
such as judicial and administrative portals, and to the 
Commission eJustice fact sheets on access to justice in 
environmental matters174. 

to 

  Ensure  that  abusive  SLAPP  suits  designed  to  deter 
legitimate  environmental  access 
justice  are 
identified  and  prevented  via  the  appropriate  means, 
e.g. via a fast track complaints mechanism. 
  Deliver an SEA portal to co-ordinate information 
on plans and programmes and consider whether 
it would be feasible to monitor the level of public 
participation in the EIA and SEA processes.  

Directives.  Teagasc  and  dairy  industry  representatives 
work  as  part  of  the  ASSAP  to  advise  farmers  in  risk 
catchment areas.  The local authority waters programme 
(LAWPRO)  also  works  with  ASSAP  to  advise  farmers  and 
improve  the  implementation  of  the  Nitrates  Directive. 
There  are  many  promotional  programmes  focused  on 
biodiversity,  including  the  national  pollinator  plan  and 
Dragon  Fly  Ireland,  citizen-science  initiatives  and  the 
National Biodiversity Data Centre  

The EPA is the responsible body for implementating and 
enforcing the IED in Ireland and have a robust system in 
place for  compliance monitoring236. The EPA carries out 
routine  inspections.  Reports  are  completed  and  made 
available within a short time frame following the site visits. 
Any observations about detected non-compliance are set 
out in the reports.  

Compliance assurance  

Complaint handling and citizen science 

Environmental compliance assurance covers all the work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, and manage waste230. It includes support 
measures provided by the authorities such as: 
(i) compliance promotion231;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring232;  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement233.  
Citizen science and complaints enable authorities to focus 
their efforts better. Environmental liability234 ensures that 
the polluter pays to remedy any damage.  

Citizen science and complaints enable authorities to focus 
their efforts better. Environmental liability235 ensures tat 
the  polluter  pays  to  remedy  any  damage.  Compliance 
promotion and monitoring 

There would appear to be strong, co-ordinated interaction 
between  relevant  stakeholders  to  promote  compliance 
with the Nature and Nitrates Directives. There is improved 
co-operation, co-ordination and information available to 
support  farmers  and  others  in  implementating  these 

230 The concept is explained in detail in the Communication on ‘EU actions 
to  improve  environmental  compliance  and governance’  COM(2018) 10 
and the related Commission Staff Working Document, SWD(2018)10. 
231 This EIR focuses on the help given to farmers to comply with nature 
legislation and nitrates legislation. 
232This EIR focuses on inspections of major industrial installations. 
233  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
234  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
235  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 

 Information about making an environmental complaint is 
readily  available  online  whether 
through  citizens 
information, 
local  authorities,  waste  enforcement 
regional lead authorities (WERLA), or the EPA. The EPA has 
a specific phone line for complaints and an online app237. 
Information on the extent and level of complaints to the 
EPA and local authorities are summarised and reported on 
by  both  the  EPA  and  local  authorities  as  part  of  their 
annual reporting. 

There are many citizen science initiatives including Citizen 
Science  Ireland238,  LAWPRO239  water  quality  monitoring, 
Explore Your Shore240 and the Dragonfly Ireland project241. 
Theseall  promote  public  participation  in  the  monitoring 
and collection of data. However, while there has been an 
increase  in  the  promotion  and  awareness  of  citizen-
science initiatives and the value thereof in the context of 
biodiversity, it is not clear from the information available 
whether this information is then collected and relied upon 
as a basis for investigations or complaints. 

236  https://www.epa.ie/our-services/compliance--enforcement/whats-
happening/access-to-epa-information-on-compliance-and-
enforcement/ 
237  https://www.epa.ie/our-services/compliance--enforcement/whats-
happening/make-an-environmental-complaint/ 
238 http://citizen-science.ie/ 
239 https://lawaters.ie/ 
240 https://exploreyourshore.ie/ 
241 https://biodiversityireland.ie/surveys/dragonfly-ireland/ 

 Environmental Implementation Review 2022 – Ireland 

 
                                                                 
 
 
Enforcement 

process bring about the intended benefits.  

Ireland  43 

The EPA, local authorities, WERLA242 and the Transfrontier 
Shipment  office243  publish  statistics  on  complaints, 
prosecutions and enforcement. The NPWS is the authority 
responsible for combatting environmental crimes related 
to birds and habitats. The NPWS in consultation with the 
Irish  Police  (Gardai)  recently  launched  a  protocol  to  co-
ordinate a joint collaboration, investigation and response 
approach  in  relation  to  environmental  crime  regarding 
birds  and  habitats244.  However,  as  there  is  no  lead 
regulator/authority  and 
the  enforcement  can  be 
complex/multi-faceted,  it  can  be  difficult  to  determine 
where responsibility/enforcement obligations lie and how 
investigations  are  co-ordinated  and  managed.  There 
seems  to  not  be  sufficient  and  easily  available  online 
information  on  the  co-ordination  and  co-operation 
between  state  agencies  on  environmental  damages  and 
crime.  Additional 
information  was  provided  by 
stakeholders, noting the role of Gardai (including NIECE245) 
and  the  co-operation  between  them  and  other  state 
bodies including the National Waste Enforcement Steering 
Committee.  However,  the  available 
information  on 
procedures for and effectiveness of co-ordination and co-
operation is limited at this stage.   

Environmental Liability Directive 

No  Environmental  Liability  Directive  (ELD)  Registry  is 
available  online.  However,  the  EPA  confirmed  as  part  of 
the  stakeholder  consultation  that  an  internal  register  is 
maintained by the EPA. In the absence of publicly available 
information,  it  is  unclear  whether  there  have  been  any 
ELD cases.  

2022 priority action 

  Make  information  available  on  the  enforcement  of 
environmental  law,  including  on  ELD  cases  and  on 
formal  arrangements  for  cooperation  among  bodies 
responsible for combatting environmental crime.   

Effectiveness of environmental 
administrations 

Administrative capacity and quality 

Central, regional and local administrations must be able to 
carry out their own tasks and work effectively with each 
other within a system of multi-level governance. 

the 

responsibility 

for  compliance  and 
Much  of 
enforcement  lies  with  31  small  local  authorities.  The 
Environmental Protection Agency (EPA) is responsible for 
licensing and controlling major industrial, waste facilities, 
wastewater discharges, the contained use and controlled 
release  of  GMOs,  dumping  at  sea  activities,  the  EU 
Emissions  Trading  Scheme  and  sources  of 
ionising 
radiation. In addition, the EPA co-ordinates environmental 
monitoring,  and  compiles  and  reports  national  data 
related  to  GHG  emissions,  air  pollutants  and  waste 
statistics.  Since  2003,  the  EPA  has  included  an  Office  of 
Environmental  Enforcement.  One  of  the  duties  of  the 
Office of Environmental Enforcement is to encourage local 
authorities to better enforce waste rules. Since 2014, Irish 
Water  has  responsibility  over  most  water  services  (both 
drinking  water  and  waste  water)  in  the  country  (before 
this, 34 local authorities were responsible). This excludes 
private  water  schemes,  mainly  in  rural  areas.  The  EPA 
regulates permits controlling discharges to water. 

Examples of electronic services available through the EPA 
include: 

  online applications for permits, including under the EID 
have  been  introduced  since  2017  with  much  of  the 
administrative  data  for  processing,  enforcement  and 
EU reporting purposes captured electronically; 

  an online Geo tool to provide nature protection data 
for projects in  special protection areas. The tool was 
developed by the EPA, in partnership with the National 
Parks and Wildlife Service (NPWS) of the Department 
of Housing,  Local Government and Heritage; 

  public databases of permits, which provide full access 
to  all  documents  (including  documents  submitted  by 
third parties); 
information  on  enforcement  activities  (site  visits, 
enforcement notices, etc.). 

 

Those involved in implementing environmental legislation 
at EU, national, regional and local levels need to have the 
knowledge,  tools  and  capacity  to  ensure  that  the 
legislation  and  the  governance  of  the  enforcement 

Coordination and integration  

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised  EEIA  Directive  provides  an  opportunity  for 

https://www.dublincity.ie/residential/environment/national-tfs-

242 http://www.werla.ie/ 
243 
office 
244 
protocol-between-national-parks-wildlife-service-an-garda-siochana-
on-wildlife-crime/ 

https://www.gov.ie/en/press-release/57bea-launch-of-joint-

245  Network  for  Ireland’s  Environmental  Compliance  and  Enforcement 
(NIECE)  is  a  network  of  organisations  and  individuals  involved  in  the 
enforcement  of  environmental  legislation,  environmental  engagement 
and promotion. 

 Environmental Implementation Review 2022 – Ireland 

 
 
 
                                                                 
 
Ireland  44 

countries  to  streamline  their  regulatory  framework  on 
environmental  assessments.  Despite  a  delay 
in  full 
transposition, 
Ireland  has  now  transposed  the  key 
elements of the revised Directive. 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments  to  reduce  duplication  and 
avoid overlaps in environmental assessments for projects. 
Moreover,  streamlining  helps  to  reduce  unnecessary 
administrative burden. It also accelerates decision making, 
provided it is done without  compromising the quality of 
the  environmental  assessment  procedure.  Ireland  has 
started  to  coordinate  its  environmental  assessments 
under the EIA and Habitats Directives. 

Environmental impact assessments are an integral part of 
the planning and industrial permitting system in Ireland, 
which  is  under  the  responsibility  of  the  Department  of 
Housing,  Local  Government  and  Heritage,  with  the  EPA 
regulating  the  industrial  permitting  system.  While  most 
planning  decisions  are  made  by  local  authorities,  the 
is 
national  planning  authority,  An  Bord  Pleanála, 
responsible  for  approving  applications  where  an  EIA  is 
required (including where the project developer is a state 
authority). The purpose behind involving An Bord Pleanála 
is to ensure greater rigour and consistency. Environmental 
enforcement bodies include the EPA and Irish Water, and 
the  NPWS.  The  shared  competency  environmental 
assessment  roles  undertaken  by  the  EPA 
include 
Appropriate  Assessments  (AA),  EIA  and  SEA.  An  Bord 
Pleanála  is  required  by  law  to  consult  a  number  of 
environmental  bodies  for  EIA  decisions.  These  bodies 
known  as  statutory  consultees)  include  the  EPA,  Irish 
Water,  and  the  NPWS.  There  appears  to  be  good  inter-
service cooperation between these bodies. 

Strategic  environmental  assessments  appear  to  be 
relatively  well  used.  Although  the  government  ministry 
responsible  for  policy  on  SEAs    –  the  Department  of 
Housing, Local Government and Heritage- – does not have 
detailed statistics on its website, the EPA provides data on 
the notifications of SEAs it receives annually. 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing programs, but also granting technical assistance 
such as the Technical Support Instrument (TSI).  

The  Commission  supported  two  environment-related 
projects under the TSI 2021 in Ireland: one to strengthen 
environmental  considerations 
investment 
management  and  the  other  on  the  reform  of  marine 
management. 

in  public 

TAIEX EIR peer to peer 

The  Commission  launched  the  TAIEX  EIR  Peer-to-Peer 
tool246  to 
learning  between 
Member State’s environmental authorities.  
. 

facilitate  peer-to-peer 

Ireland  participated  in  four  multi-country  workshops  on 
circular  economy  for  cities  (2019),  sustainable  urban 
development  (2019),  ammonia  reducing  technology  and 
measures (2021) and zero pollution (2022). 

246  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu) 

 Environmental Implementation Review 2022 – Ireland