Submission to Draft NECP FEbruary 2019

25th February 2019
Submission Summary

Key Points in this Submission

  • Ireland’s Draft National Energy and Climate Plan (NECP) fails to deliver energy or agriculture emission reduction, or any coherent climate action aligned with commitment to the Paris Agreement. Therefore, it requires urgent revision by the end of 2019 to ensure that the finalised NECP includes ambitious plans for substantial and sustained reductions in annual GHG emissions.
  • The Draft NECP (hereafter “the Draft”) shows no realisation in government that greenhouse gas (GHG) emissions must now go down very fast, no matter what. The climate system does not “care” about economics or population, only about accumulating amounts of long-lived climate pollutants, carbon dioxide and nitrous oxide, and changes in emission rates of shorter-lived GHGs such as methane and black carbon. This is what a mitigation imperative means.
  • All four Draft scenarios fail by approximately only ‘flat-lining’ total annual fossil fuel CO2 emissions from 2015 to 2040, thereby continuing to add about the same amount of CO₂ every year to accumulate further in the atmosphere.
  • The Draft is not constrained by any stated quota limit to cumulative CO₂, to be aligned with a fair share of the global carbon budget for the Paris temperature objectives, therefore it is not a climate action plan that is coherent with the EU’s or Ireland’s own climate plan.
  • The Draft even fails to show scenarios coherent with Ireland’s existing climate policy, widely understood as a linear annual reduction in CO₂ to at least an 80% reduction in 2050 compared to 1990
  • The Draft’s data projections show no reduction in annual GHG emissions from agriculture and land use to 2035 – methane and nitrous oxide emissions from livestock and nitrogen fertiliser use increase. Therefore no approach to carbon neutrality in this sector is shown nor any contribution from it to overall decarbonisation as required by the National Policy Position2.
  • The Draft should assume emission reduction as a driving imperative that must be met by economy-energy modelling within the ‘fair share’ carbon budget limits of the Paris objectives. But instead, contrary to the European Governance Regulation (EU-GR) requirements, Ireland’s Draft NECP assumes that business-as-usual demand growth will be met without decarbonisation.
  • The Draft shows a move to lower carbon intensity fossil energy in energy supply – less coal and peat, but much more gas and little change in oil use. Paris requires urgent reductions in aggregate oil and gas COⁿ emissions as well asfrom coal and peat.
  • The NECP proposes some exploratory investigation of the potential for deployment of(still high cost and immature) carbon capture and storage technologies (CCS), butthe scale and timing is not quantified in detail, the scope is limited to natural gasand industrial process emissions only (i.e. not oil) and certainly would remainminimal in the period to at least 2030. That being the case, deep emissions reduction are already urgently required within that period that can only be effectively achieved by commensurate absolute reductions in consumption of all fossil fuels beginning immediately.
  • The Draft is based on projected increases in emissions from agriculture, which cannot be offset by mitigation in other less prolific emitting sectors. As such the Draft is a plan for increases which breach the linear reduction pathway needed in the 2020-2030 period and exposes the State to substantial and potentially punitive compliance costs. This is not a responsible course of action for government to advocate.
  • The Citizens’ Assembly recommendations should have been addressed in the Draft and must be in the final report, the urgency now needed for climate action requires it.
  • Stranded asset investments in gas infrastructure such as the proposed Shannon LNG terminal must not be pursued. It is a waste of time and resources to invest in a high carbon fuel that only adds to unsustainable energy and climate insecurity.
  • In terms of Climate Action Network Europe’s five pillars for transformative NECPs3 we find that the Draft: fails to deliver sufficient ambition; does not meet a long-term Paris check; has policies that are incoherent and lack consistency even with existing plans; uses technical loopholes (undermining climate mitigation effectiveness) and fails to report all fossil fuel subsidies.
  • The Draft was published in a barely readable light blue font with a large ‘DRAFT’ watermark. This is a basic communications error that needs to be avoided in future,. Even a draft plan needs to be in an easily readable black font with no watermark.
  • On transparency, DCCAE’s NECP consultations have shown a welcome increased commitment to publishing data (as required by the EU-GR). However, the Draft fails to show how views were taken into account if at all. For example the basic point that limiting future cumulative COⁿ is core to climate action has been ignored although it is clearly