The recently published Climate Action Plan 2023 is an impressively constructed response to Ireland’s urgent need to meet its domestic and international obligations to reduce its greenhouse gas emissions. The plan runs to 284 pages and provides a sector-by-sector analysis of where we stand and what steps will be taken to meet the requirements of the Climate Action and Low Carbon Development (Amendment) Act 2021.
A perusal of the action plan reveals that mention of 2030 appears 279 times in the document. By comparison, 2025 appears only 184 times. This would seem to confirm that the primary emphasis of the Plan is to meet a notional, and still conveniently remote, 2030 “target” of reducing emissions by 51 per cent on a 2018 base year. Such a reduction is mentioned in the Act, but not as a target (much less a statutorily binding constraint). Instead, it was laid down as a parameter for the guidance to (“provide for”) the Climate Change Advisory Council in preparing its initial GHG [greenhouse gas] budget proposals.
However, this 2030 consideration has now been entirely superseded by the two legally binding carbon budgets for the periods 2021-25 and 2026-2030. These identify maximum emission tonnages of 295 and 200 million tonnes of greenhouse gas emissions respectively. These budgets were recommended by the Climate Change Advisory Council as part of its independent legal remit and were then endorsed by the Government and Oireachtas. Accordingly, these five-year carbon budgets are the binding limits to be respected under this and future climate action plans.
Failure to live within the 2021-25 budget allocation will be subtracted from the 200mt [megatonne] budget for 2026-2030
To take an analogy from the financial world, we do not talk about target spend but rather budget allocation. For example Budget 2023 did not have a target to achieve spending of €997 million on defence by the end of the year, rather the allocation given provided for a maximum expenditure of that amount for the period concerned. Similarly, therefore, what matters most immediately in the 2023 Climate Action Plan is not a remote 2030 target, which is likely at least two elections away, but the urgency to stay within the maximum allocation of 295mt [megatonnes] permitted for the period 2021-2025: ie, the measures needed to dramatically reduce emissions in each of the next three years.
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This distinction is a serious one. Any failure to live within the 2021-25 budget allocation will be subtracted from the 200mt budget for 2026-2030. Politically, this would therefore fall to the next government to meet its legal obligations — something that would pose great difficulties given the much more restricted allocation for this second five-year period.
The second stage of operationalising the Climate Change Act came in July 2022 with the publication of sectoral emission limits for a number of sectors. So in the case, for example, of agriculture the budget for 2021-2025 was established as 106mt out of the 295mt overall budget, and for transport as 54mt out of the 295mt budget. Confusingly, however, two further columns were added to the sectoral emissions ceiling document: “Indicative emissions in the Final Year of the 2021-2025 carbon budget period” and “Indicative reduction in emissions in the Final Year of the 2021-2025 carbon budget”. By identifying an individual year (2025) these provide irrelevant targets when the central legally binding requirement is adherence to the five-year budget. The values reached in the year 2025 per se are not what is legally mandated by the Climate Act.
The question arises as to whether the 2021-25 emission reductions are seen as the primary objective or some kind of intermediary towards a notional (but entirely non-statutory) 2030 reduction of 51 per cent. This blurring is not helped by the positioning of an approximate (~) symbol beside the “Indicative reduction in emissions in the Final Year of the 2021-2025 carbon budget” column. Is for example agriculture bound by a 10 per cent emission reduction over the 2021-25 period or not?
It would be best to allow contingency … by proactively reducing the ceilings in some of the more generous other sectors, such as agriculture
More serious problems arise when the individual sectoral limits are aggregated. For the 2021-2025 period, they total only 275mt. This seems comfortably within the 295mt budget; except no allocation has yet been made for Land Use Land Use Change and Forestry (LULUCF). The Minister has therefore not completed the sectoral limits exercise and has used the Climate Act provisions to delay establishing a ceiling for this sector on the grounds that additional information is required concerning current and future trends. The report on LULUCF will reportedly be used to incorporate the remaining LULUCF sectoral limits “as soon as may be” and not later than the end of 2023. But a maximum of 20mt is available from the remaining carbon budget for this category. It is extremely difficult to reconcile how this can be incorporated into the existing legally mandated budget system. In their baseline year of 2018, the Climate Change Advisory Council estimated that LULUCF was coming in at 4.8mt per annum. Even if this figure was to remain constant for the period 2021-2025 the overall carbon budget would be breached. However, the Environmental Protection Agency has now projected that annual (LULUCF) emissions may rise to 11mt in 2030, suggesting that immediate mitigation measures are required.
Given this, the risks are clearly towards significant budget overshoot. Applying the precautionary principle, it would be best to allow contingency for this by proactively reducing the ceilings in some of the more generous other sectors, such as agriculture. As an aside, the precautionary principle is also disregarded in the second five-year budget where the existing sectoral limits exceed the provided-for budget even without an allocation for LULUCF and reconciliation is achieved by an unexplained “unallocated savings” of 26mt.
The incomplete sectoral emission limits may however be further undermined by the failure to address emissions at a wider level. The year 2021 was marked by an increase in greenhouse gas emissions to 69.3mt by comparison to the 2018 baseline of 68.3mt. As such, 23.5 per cent of the five-year budget is already expended, before the 2022 figures have emerged. Should these indicate a further increase overall, the country may be in a position where almost half the five-year budget has been expended in the first two years. Meeting the legal requirement with or without relief from LULUCF may be very problematic indeed! Urgent action by the Government is required: procrastination is a recipe for budget overshoot and the serious legal implications that may follow.
- John Sweeney is professor emeritus at the Department of Geography at Maynooth University