The Government’s new National Biomethane Strategy (NBS) abjectly fails to address the multiple and very serious issues raised by An Taisce and by the Environmental Protection Agency (EPA) during the public consultation. As required by the Aarhus Convention, the purpose of public consultation is to improve draft proposals but the final NBS shows that this has not happened.

Therefore, the Departments of Agriculture (DAFM) and Climate (DECC) are open to an Aarhus complaint and it is now entirely possible that large amounts of public monies will be spent supporting a Strategy that may deliver little or no climate benefit and could likely increase nitrate water pollution and ammonia emissions, contrary to Ireland’s international commitments.  

The EPA submission strongly advised that, to reduce the risk of poor implementation, “the Strategy should clearly set out the actions, targets, timeframes and responsible owners for implementation”. The new NBS provides no such clarity, therefore the Strategy and the Green Gas Certification Scheme lack credibility.

An Taisce’s submission raised a number of credible and serious concerns, based on peer-reviewed and EU report evidence. However, the updated NBS does not address any of this evidence directly, and it fails to provide any certainty that the Strategy will be backed by effective regulatory measures and to ensure sustainability concerns are met. 

Consequently, the Strategy does not evidence meaningful public engagement by the Departments. The Strategy lacks transparency: it is unclear what is being signed up to, what risks are entailed, what benefits are likely relative to alternative options, nor how much the Strategy’s delivery will ultimately cost the public purse. 

The Government is now seeking €40 million in capital funding from the EU, but even in outline form the NBS does not remotely satisfy the requirement on public bodies to evaluate, plan and manage public investment. 

It is likely that this NBS will primarily act to support greenwashing of fossil carbon “natural gas” delivery and increase the economic viability of emissions-intensive milk and meat production. System change to resilient national energy and agri-food systems is urgently required, but the NBS mostly reinforces the business-as-usual model for Irish agriculture which is unsustainably imbalanced toward intensive livestock production. 

Rather than being evidence-led and society-centred, the NBS states it will be "agri-led and farmer-centric". The updated NBS text overtly embeds bias toward vested interests by allowing industry stakeholder influence over its implementation and governance.

The only substantive improvement in the NBS relative to the Draft version is a new section on the (previously unmentioned) importance of minimising methane leakage from anaerobic digestion (AD) plants. However, this section fails to address the seriousness of the issue: it ignores the peer-reviewed international evidence showing unsustainably high methane losses from existing AD plants and instead cites only a biogas industry study.

Otherwise, the revised Strategy has ignored all of the key issues raised by the EPA and An Taisce, including the need for rigorous independent oversight, enforced limits on chemical nitrogen use in feedstock production, minimising AD plant impacts on communities, and limiting pollution from use of the digestate by-product as a fertiliser. 

The credibility of the NBS or "Green Gas" credits as “sustainable” or significantly reducing climate impact relies on having an arms-length regulatory agency with clear enforcement powers and separate resources. But the NBS entirely fails to identify the crucial importance of independent regulatory oversight, by the EPA or any other agency, and makes no provision for the necessary annual budget requirement to cover that function. 

These issues strongly indicate that large scale AD biomethane should not proceed without assessing far smaller scale roll-out first, and modelling of alternative options, which may be less costly and come with lower environmental impacts. In summary, the NBS is highly liable to further support existing business as usual vested interests at substantial public cost for little climate or environmental benefit. 

Collectively, we need to outline an energy and land-use transition that is demonstrably aligned with meeting Ireland’s agreed carbon budgets and producing food and energy within ecological limits to guide society and farming to the most resilient possible future. By failing to meet these crucial parameters, the new National Biomethane Strategy is not up to the task.