Submission to National Climate Policy Development Consultation

Download: Environmental Pillar Climate Submission


Long-term effectiveness
Transition to a low-carbon economy
Environmental sustainability
Approaches to policies and measures
Putting a price on greenhouse gases
Information and awareness
Carbon Budgets
National Mitigation Plans
Annual Transition Statement
Expert Advisory Body
The Environment Pillar welcomes this consultation on national climate policy and looks forward to further opportunities in appropriate fora to elaborate its views and recommendations on the formulation of a truly effective national response to climate change.
At the outset, we wish to emphasise the importance of the rapid introduction of national legislation for the implementation in Ireland of a progressive, robust, equitable and adequate response to both the causes and consequences of anthropogenic interference with the climate system.
Climate change remains the defining challenge of our age. The Environmental Pillar shares the National Economic and Social Council’s analysis[1] that “addressing it will have far reaching economic and social effects”, and that “Ireland’s greenhouse gas emissions target for 2020, yet to be finalised”, “will pose considerable challenges” and, most significantly, that “the move to a low-carbon economy will also create many new economic opportunities.”
Irish climate policy over the last two decades has been dominated by the need to comply with EU common climate policy and EU regional implementation of the United Nations Framework Convention on Climate Change (UNFCCC) and since 1997 its Kyoto Protocol (KP).
National policy has for many years been driven by fear of mitigation commitments and not by the possibilities for climate policy to drive economic advantage and competitiveness in a 21st century context of decarbonisation and a green economy.  For many years therefore, Irish policy has been to concentrate on maximising the possibilities offered by the internal differentiation of the EU’s overall KP target, into perceived advantage in terms of reduced stringency in Ireland’s international mitigation commitments.
Ireland’s KP first commitment period (CP-1) target was/is therefore only a commitment to limit the rise in Ireland’s emissions to 113% of 1990 emissions for the average of the 2008-2012 CP-1 period.
By comparison, non-EU European countries generally have far more stringent CP-1 targets than Ireland (Switzerland, Liechtenstein, Monaco, 92%; Norway 101%; Iceland 110%).
As a contracting Party however, Ireland also has direct, distinct, and entirely national obligations to the provisions of UNFCCC which are not negated by membership of the EU.
Chief amongst these is the obligation on Ireland under UNFCCC Art. 3.1 to protect the climate system for the benefit of present and future generations on the basis of equity within an overall framework of common but differentiated responsibilities and respective capabilities (CBDR-RC) and, as a developed country, to take the lead in combating climate change and the adverse effects thereof.
In terms of historic responsibility for causing anthropogenic climate change, Ireland ranks 24th in the world in terms of per capita cumulative CO2 emissions since 1990—not as high as many other EU member states due to Ireland’s rather later industrial development, but far higher by an order of magnitude than many developing countries (166 tonnes CO2 per capita in Ireland, 16 tonnes per capita in India, 4 tonnes per capita in least developed countries in Africa)[2].
In terms of current responsibility for climate change, Ireland again ranks 24th in the world in terms of CO2 emissions from energy use, producing 11.1 tonnes per capita in 2008 (8th highest in the EU) again an order of magnitude greater than in many developing countries (1.3 tonnes per capita in India, 0.4 tonnes per capita in least developed countries in Africa) [3].
In terms of economic capability, Ireland is amongst the wealthiest countries in the world, ranking 9th in the world, at almost 40,000 international dollars at purchasing power parity per capita in 2008 (2nd wealthiest in the EU) and again an order of magnitude greater than many developing countries ($2,780 in India, $1,500 in least developed countries in Africa, $5,700 in China)[4].
In terms of capability to substitute renewable energy supply (RES) for fossil energies—essentially the major challenge in tackling dangerous interference with the climate system—the exact scale of the Irish RES resource has never  been precisely  quantified.
SEAI have publicly-available wind and solar radiation maps (at rather coarse scale) but no apparent attempt has ever been made to accurately quantify national solar, wind, ocean and potential biomass resources combined in an integrated assessment of potential national total RES resource over time, allowing for both technical and technological improvement(s) along with cost assessment(s) of investment demand(s) discounted for price improvements generated by continuous scaling-up of RES deployment.
Lack of such a resource assessment already represents a significant deficit in national climate policy. Furthermore, in the context of this particular consultation, absence of such an assessment poses a question about the validity of views on energy choices and energy policy frameworks (and therefore mitigation ambition) when the consultation has not made essential information on alternatives to fossil fuels available to the general public.
Nevertheless, in the light of the partial information that is currently available, it is highly probable thatIrish RES resources per capita are amongst  the very best in the world.
Taken together in the light of UNFCCC Art 3.1, Irish responsibility for excess emissions in the climate system is high (whether considered cumulatively, or currently) and Irish capability to mitigate those emissions is even higher (considered as both quantity of RES resource, and availability of economic resources available to exploit RES).
As an EU member state, Ireland is bound to the longstanding EU objective of stabilising global temperatures at a level below 2oC above pre-industrial temperatures.
Achievement of this objective will depend not only on the EU, but on all Parties to UNFCCC putting themselves onto sustainable and solid decarbonisation trajectories extending from the present day through a principal short-term “milestone” objective for 2020 and continuing onward to at least a mid-to-long term milestone objective for 2050.
Currently, the EU’s negotiating position in the UN negotiations is that global emissions will need to be halved from present day levels if temperatures are to be stabilised at 2oC.
In fact, scientific evaluation is that this degree of global decarbonisation only provides a 50% certainty of not overshooting the 2oC mark.  The precautionary position would therefore be that global mitigation ambition should be far greater than a halving of global emissions by 2050.
For reasons already elucidated, within a global agreement based on the UN principle of CBDR-RC, Ireland has an exceptionally high capability to mitigate emissions, and a very high responsibility to deploy that capability. The aim of new national climate policy should be to deploy adequate resources within a solid and legal-binding framework capable of meeting Ireland’s mitigation challenge while simultaneously leveraging the opportunities offered by conversion to a competitive green economy.
Ireland’s overall mitigation objectives must obviously be strongly informed by the IPCC 4th Assessment report (2007), which contains an evaluation that to stabilise greenhouse gas concentrations at a level of 450 ppm in the atmosphere (equivalent to an approximately 50% chance of not overshooting 2oC) industrialised nations must aim to reduce their emissions by 25% to 40% from 1990 levels by 2020, and by between 80% and 95% (from 1990 levels) by 2050 [5]. (Most developing countries will also have to deviate substantially from a business as usual baseline by 2020, and all of them by 2050).
Currently, the EU legal basis is that the EU will commit to a 30% reduction from 1990 levels by 2020 within the context of a comprehensive international agreement to mitigate climate change. Such an agreement has since been decided by UNFCCC (at Durban in 2011) to be completed before 2015.
Ireland’s current legally-binding target under the EU effort sharing decision (ESD) is to reduce non-ETS emissions by 20% from 2005 levels by 2020 as part of an overall EU commitment to a reduction in emissions of 20% from 1990 levels by 2020.  There is no reason to believe that Ireland’s target for 2020 following completion of an international agreement will not be at least a reduction of 30% from 2005 by 2020.
National climate policy should therefore be totally predicated on reducing national emissions to below 30% below 2005 levels (11% below 1990 levels) by 2020 at the latest. The precautionary approach (as informed by IPCC work) would be to aim for even deeper reductions.
For 2050, as already outlined, the IPCC evaluation is that Ireland’s mitigation objective will have to be a reduction of at least 80% from 1990 levels (84% from 2005 levels) by 2050.
For reasons of equity, and based on the CBDR-RC principle, Ireland’s 2050 target should in any case be at least this. Current global emissions of c. 45 Gt shared amongst a global population of c. 7.2 billion people implies a global allowance of c. 6 tonnes per capita (roughly equivalent to Chinese levels currently).  Halving global emissions implies a 2050 allowance of well below 3 tonnes per capita (for all gases) in that year, even if global population expands only marginally.  3 tonnes per capita (for all gases) would represent an 80% reduction from current Irish levels.
It should be noted that should the UN and/or the EU independently decide to lower the temperature stabilisation objective to  1.5oC (or some figure intermediate between that and 2oC) then the Irish mitigation pathway to 2050 will have to be steeply sharpened  into one that is emissions-negative not too far beyond 2050
Climate legislation (see section below) should therefore contain an explicit provision allowing necessary adjustment for any such eventuality.
The United Nations Environment Programme (UNEP) defines a green economy as:
A system of economic activities related to the production, distribution and consumption of goods and services that result in improved human well being over the long term, while not exposing future generations to significant environmental risks and ecological scarcities”. [6]
Greening the economy is essentially about improving human well-being, while significantly reducing environmental risks and ecological scarcities. Investments in greening key sectors of the economy, and adopting related policies and strategies, can lead to a healthy population. Moving away from the conventional “grow first, clean up later” path of development into a “green” path of development can result in a healthy socially inclusive, productive, equitable and more resilient society..
A green economy is one in which ecological assets are considered to be at the core of long-term wealth. These assets must be managed as a source of prosperity and well-being.
One of the major findings of the UNEP Green Economy Report is that a green economy supports growth, incomes and jobs, and that the so-called trade off between economic progress and environmental sustainability is a myth.
If Ireland is to succeed in making the transition towards a low carbon competitive economy by 2050 transformation must begin now, including the following actions, inter alia:

  • Make the transition a national priority, led from the Office of the Taoiseach,  embedded in all government departments, local authorities and all sectors of the economy and supported by effective legislation;
  • Investing in clean energy, waste minimization, resource efficiency and ecosystem enhancing activities;
  • Building on existing international/national indicators for measuring the transition, including the shift in investments (as for example in the case of UNEP/REN21’S regularly published status of investments in renewable energy);
  • Cutting perverse subsidies to, and discourage investment in, high emission, heavily polluting, waste generating, resource intensive, and ecosystem-damaging activities;
  • Investing in research in alternatives and encourage investment in resource efficient and non-polluting activities, in inter alia agriculture, health, buildings, cities, energy, forests, manufacturing, tourism, transport, waste, water;
  • Increasing carbon taxes in accordance with the Polluter Pays principle so that the carbon content of  all fossil fuels is taxed equally;
  • Introducing forestry incentives for carbon sequestration in a manner that supports Ireland’s biodiversity obligations and other sustainability goals, with a major focus on native, deciduous, biodiverse woodlands.

Our green assets are the foundations on which to build a low -carbon green economy in Ireland. In order to ensure that Ireland benefits fully from the opportunities associated with these assets, action should begin now by:

  • Promoting their importance as a national objective for our long term wealth and well-being;
  • Highlighting the interlinkages between health, trade, jobs and the green economy;
  • Investing in sustainable agriculture and biodiversity-friendly business where trade opportunities are growing rapidly (global trade in organic food, drinks, fibre and cosmetics is over US$60 billion per year);
  • Expanding the public transport system and radically increasing energy efficiency across all sectors.

Indicators for measuring progress towards a green economy are essential as well as compliance to and enforcement of environmental law.[7]
The transition to a green economy will require strong leadership and political will supported by a groundswell of support.
The following core criteria should be used for the selection of policies and measures:
Long-term effectiveness
Policies and measures must be consistent with the long-term goal of the UNFCCC to avoid dangerous anthropogenic climate change and with emissions scenarios which will achieve that goal.
Transition to a low-carbon economy
Policies and measures should form part of the transition to a low-carbon economy. While this criterion overlaps the previous one somewhat, it is useful to list it separately as it places the emphasis on the integration of sustainability and climate change goals into economic policy.
Environmental sustainability
Policies and measures must be consistent with environmental sustainability, including sustainability criteria other than climate change such as protection of biodiversity, avoidance of pollution, etc.
Policies and measures must be equitable and/or promote equity within Ireland and on a global basis and indeed, in other countries insofar as they affect equity within those countries.
Use of Marginal Abatement Cost Curves (MACC)
Climate change policy in Ireland has traditionally relied on marginal abatement cost curves to inform the selection of policies and measures.  Such analysis is indeed of value. However, if it is not to lead to sub-optimal results, it must be complemented with consideration of the co-benefits of some mitigation options (see below) and it must be applied with regard to long-term as well as short term costs in the context of a transition to a low-carbon economy
Some climate mitigation options, especially in the fields of transport and housing will deliver very significant co-benefits in areas as public
health.[8]  These co-benefits must be taken into consideration when selecting policies and measures.
Approaches to policies and measures
Putting a price on greenhouse gases
This is universally recognised as a key element of climate change mitigation. Equity is a key consideration when it comes to carbon pricing.  An equity-based approach is also essential to the effectiveness and adequacy of the pricing signal; it will be politically and economically impossible to achieve a sufficiently high carbon price unless there is a trusted and reliable mechanism recycling the revenue from the higher price to citizens within a robust, transparent and equitable framework thoroughly grounded on the basis of responsibility and capability.
Therefore, as previously recommended in our Budget submission,[9] we recommend the adoption of a pricing mechanism which is equitable by design, for instance Cap and Share, Cap and Dividend or other pricing proposals as documented in Building the Climate Regime.[10]  ‘Grandfathering’ of emissions as was initially the case in the EU ETS is unacceptable both on equity grounds and because it distorts the necessary incentives to emissions reduction
Linked to but distinct from the current price of greenhouse gases is the factoring into  decision-making of anticipated future carbon prices. ENGOs have pointed out for some time[11] that official guidance in Ireland[12] predicts far lower future carbon prices than that in other OECD countries, and that if followed, this guidance will lead to lock-in to high-emissions and high-cost development pathways. We recommend that long-term decision-making including infrastructure planning be based on scenarios of transition to a low-emission economy compatible with the achievement of the ultimate objective of the UNFCCC and that assumptions about future greenhouse gas prices be based on this transition.
ENGOs have pointed out for some time that there are major subsidies to fossil fuels in Ireland[13]. The most striking perverse subsidies are those to peat-fired electricity, motor vehicles (in particular goods vehicles), internal and external aviation, and fertilisers. Of these, the only subsidies to be even somewhat addressed in recent years are indirect subsidies to internal aviation. Internal aviation (as much as international aviation) is still highly subsidised by no tax on kerosene. We recommend yet again that all perverse subsidies to fossil fuels and fossil fuel consumption be removed.
Because of the inherent inadequacies of markets, regulation is an essential element of climate change policy. We recommend continued and tighter regulation in such fields as emissions from motor vehicles, lighting, buildings, etc. Such regulation needs to be cleverly designed to avoid perverse incentives. We advocate that even if regulations are in place at EU level, Ireland should be prepared to introduce tighter regulations, and similarly, local authorities should be able to introduce tighter regulations than national governments. Such regulation on a smaller scale, while inefficient according to economic theory, tends to work very well in practice as it serves as a pilot which demonstrates the feasibility of the higher standard[14].
Many energy demand reduction measures suffer from split incentives. The classical example is the landlord who has no incentive to reduce her tenant’s energy bills. Information in the form of mandatory BER will help to a degree (when it is enforced), but regulation in the form of minimum acceptable BER (for non-heritage buildings) is also required.
Information and awareness
Information is key to individual action on climate change. Good work is done by local energy agencies and SEAI in publicising energy conservation and demand management. There is little effective awareness raising on other aspects of mitigation such as agricultural emissions or carbon sinks.
When the consultancy contract to run the Change campaign was terminated NGOs were assured that the DECLG would continue to run the campaign and to raise awareness on climate change. This has not happened. The information on the website which replaced the website appears not to have been updated since about 2008 or 2009.[15]  We are unable to find any assessment of the Change campaign on the DECLG website or elsewhere. If such an assessment is available we would be eager to consider and discuss it.
We recommend that a significant climate change awareness programme be put in place.
We recommend that the requirement for including BER on all property advertising as mandated by the recast EPBR be implemented promptly.[16]
Ireland’s experience with environmental and other taxation and incentives shows that their impact can often be significantly greater than economic theory would predict. This is particularly the case with incentives directed at the general public, such as the plastic bag tax and the redesign of vehicle registration tax on a CO2 emissions basis. We recommend that Ireland continue to develop both positive and negative incentives which will drive the transition to a low-carbon economy, especially those likely to tap into a latent willingness to change and thereby have an impact in excess of their purely economic leverage.
A major issue with many energy demand reduction measures is the difficulty those who would benefit have in financing the capital investment.  This financing problem falls particularly heavily on the fuel poor and therefore is a major issue for equity, social inclusion and public health. The national goals of reducing energy demand and GHG emissions will fail unless financing is available; this will require government intervention, for example an independent non-profit State-guaranteed trust acting as a mechanism for the delivery of financing as well as quality assurance.[17].
Additional to specific issues identified and addressed above, a general observation is that an attempt (as in questions 7-12 of the questionnaire) to rank categories of policies and measures is unlikely to be useful. The measures are generally complementary rather than alternative to each other and different measures are applicable to different aspects of an overall climate change mitigation strategy.
Climate change legislation will put in place the architecture that Ireland needs to move towards a low carbon economy. The Environmental Pillar welcomes the commitment to climate legislation in the programme for government and the Department of the Environment’s Roadmap for Climate Legislation.
A strong and effective climate law will ensure a whole-of-government approach to climate change mitigation that moves away from a silo mentality within departments. The three main planks of climate legislation are targets, carbon budgets and an expert committee on climate change. Legislation should contain and be supported by Climate Change Strategies.
The UK government passed a climate change act into law in autumn 2008[18]. An even stronger bill was passed in Scotland in 2009[19].
In a framework document published in late 2009[20] the Irish government has indicated that our own act will draw strongly on the UK and Scottish models.
We wish to see Irish legislation that achieves at least the same level of robustness and innovation as reached by our neighbours in their climate legislation.
The Fourth assessment report of the Intergovernmental Panel on Climate Change shows that only a narrow window of opportunity exists to address the serious negative effects of climate change.
Ireland and other high-income OECD countries must take responsibility for deep emissions cuts by 2020 and aim for a carbon neutral economy by 2050 (net zero emissions). In order to be effective the Act must have a binding 2020 target.
The Pillar believes that legislation must specify an annual decarbonisation rate from the year of entry into force, which ensures that a binding 2020 target can be clearly derived and that corresponds to a minimum of 30% reduction through domestic action by 2020 on 2005 levels.
Irish legislation should ensure that the vast majority of these reductions are achieved through purely domestic action.
The legislation should aim to harness Ireland’s vast store of potentially-available renewable energy resources to available technologies and human capital, thus simultaneously creating enterprise and employment along with the emissions reductions.
Climate legislation is a basic building block in empowering all these actions.
The Environment Pillar considers it extremely important that emissions reductions actually happen in Ireland rather than giving a false appearance of reduction through bought-in offshore credits (Flexible Mechanisms).
Carbon Budgets
Legislation must establish legally binding mulit-annual carbon budgets that lead convincingly to a 2020 target. Such budgets provide certainty to businesses, households and politicians about where emissions levels will be by a given date.
In a world where politics is dominated by the 24/7 news cycle and the 5-year electoral cycle a legally binding target must be constantly in sight for policy makers to be beholden to.
Good climate legislation is about hardwiring accountability on climate change into the political system.
The proposed Bill should provide for the setting of 5-year targets (as a minimum) by Government. This would be well aligned with the electoral cycle of political accountability and would therefore be a spur to timely action.
National Mitigation Plans
National Mitigation Plans should be used to support legally binding five yearly carbon budgets. When the UK government published its first 5-year carbon budget it also published a plan called Building A Low Carbon Economy. In the same way that this Plan provides the strategies and polices to meet the targets, so must National Mitigation Plans lay out the policies to meet the Targets and Budget in the promised Bill.
Ireland’s previous two climate change strategies proposed many measures that were never implemented. Future plans will only succeed if backed by five year legally binding carbon budgets.
National Adaptation plans should also follow this model of shadowing the five-yearly carbon budgets.
Annual Transition Statement
Linked to the Carbon Budgeting process should be Annual Transition Statements to the Dáil.
These Annual Transition Statements should contain an indicative target for the following year, and also indicative sectoral targets for the coming year.  These budgets must be agreed by Cabinet before the responsible minister presents them to the house. The composite (national) annual carbon budget should be in line with the advice of the Expert Advisory Body and should also be subject to EAB’s scrutiny and evaluation.
When the minister presents the Annual Transition Statement to the house this should be debated openly by the Dail. During this debate the Minister will be required to report on emissions for the previous year and respond to gaps between trajectories to targets and actual emissions. The Minister must also respond to the advice of the EAB as part of the Statement, stating what advice is being taken by government and explaining why not, if advice is not being taken.
Expert Advisory Body
The Environmental Pillar supports the model of a national, independent climate change committee to provide expert counsel and advice to the government on the design and implementation of national plans for cutting emissions and adapting to climate change. The expert body should also act as the eyes and ears of the public in ensuring that Ireland plays its full part in the global effort against climate change
The committee should be composed of at least 9 independent experts in their field, covering the areas of climate science, forward-looking economics and mitigation policy.
The committee needs to be independent and transparent in all its dealings.
The composition and work of the Committee should be public-oriented, and its proceedings, hearings, and advice easily accessible to the public. Public scrutability will ensure accountability and credibility and should improve compliance.
For further details please contact
Michael Ewing, Coordinator.
Environmental Pillar of Social Partnership
Tullyval, Knockvicar, Boyle, Co Roscommon
Telephone: 00353 (0)71 9667373, Mobile: 00353 (0)86 8672153
Whilst this document was developed through the processes of the Environmental Pillar it does not necessarily represent the policies of all its members.


[1]  NESC Report 117, page xvi
[2] Source: Climate Analysis Indicators Tool (CAIT) Version 9.0, World Resources Institute, Washington, DC, (2008 is the most recent year for which full data for all countries is available).
[3] Source: ibid.
[4] Source: ibid.
[5]  Box 13.7, IPCC AR4 Working Group III, 2007
[6] UNEP’s Working Definition of a Green Economy:
[7] There is scarcity of data and indicators needed to catalyze the transition to a green economy  in terms of investments, outputs and jobs in environmental sectors for e.g. renewable energy technologies, public transport, waste management, and recycling.
[12] Department of Finance, 2009, Guidance Note on Incorporating CO2 Emissions into Capital Project Appraisals
[16] Art. 12 (4) of Directive 2010/31/EU on the Energy Performance of Buildings (recast)