The need for urgent climate action is ever more apparent but nationally, until now, it has been unclear what limits on emissions must be met. A few weeks ago we submitted An Taisce’s written response to the Public Consultation on the first Carbon Budgets programme proposed by the Climate Change Advisory Council (CCAC) in October 2021. The aim of carbon budgeting is to set out limits for Ireland’s future greenhouse gas (GHG) emissions from energy, agriculture and land use aligned with a fair share of global climate action.

The carbon budget programme was approved by the Oireachtas at the end of February, covering three successive 5-year carbon budgets from 2021 to 2035. In addition, the roll-out of a carbon budget programme that is consistent with the Paris Agreement goal to avoid dangerous climate change is one of the requirements of the Climate Action and Low Carbon Development (Amendment) Act that was signed into law last year.

Based on the key recommendations of An Taisce’s submission, here I’ll outline the disparities between the approved budgets and Ireland’s national and international climate obligations. 

Reduce Budgets, Reject Backloading

The budgets are not in line with the Paris Agreement goal or Programme for Government targets because they do not require equitable action in a timeframe that reflects the critical urgency of the climate emergency.

1. The Paris Agreement aims to limit warming to 1.5°C above pre-industrial levels, and requires all parties to the agreement to reduce emissions across the entire economy. The proposed budgets need to be significantly reduced to meet the Paris temperature goal, and need to provide for emissions from industries and activities which have not been included in budget calculations (such as shipping and aviation, and bottom-trawling). 
2. The carbon budgets need to be front-loaded i.e. greater reduction requirements need to be placed on the first budget period from 2021-2025. Offloading greater emissions reductions to the second budget period delays urgent and critical action and makes action during the second budget period exceedingly difficult.  

Own It (Historical Responsibility, that is)

The carbon budget programme needs to adequately consider Ireland’s historical responsibility for climate change. Ireland has been accessing and utilising the finite global carbon pool through continuously high emissions, so much so that we are now on the brink of going into carbon-debt.

1. The CCAC used 2020 as the baseline year for calculating emissions reduction targets. This essentially wipes Ireland’s historical emissions slate clean before 2020. The reference year used needs to reflect Ireland’s historical responsibility for climate change and, on this basis of equity, the reference year should be no later than 2015, when the Paris Agreement was adopted. 
2. The Paris Agreement requires equity-based action and prescribes a common but differentiated responsibilities and respective capabilities approach. This obliges developed nations to take actions to reduce emissions in line with their historical responsibility for climate change and their enhanced ability to act. Based on Ireland’s historical responsibility for climate change and current emissions, we will exhaust our ‘fair share’ of the remaining global carbon budget in the next 3-5 years.

Equivalent in Name Only

Carbon budgets are outlined for each period in terms of carbon dioxide equivalency, but not all GHGs have the same warming effect as carbon dioxide. Therefore, the makeup of emissions at 2030, and not simply the “carbon dioxide equivalent”, will play a significant role in determining the carbon budgets’ consistency with the 1.5°C Paris temperature goal. 

1. The carbon budgets programme must consider the makeup of emissions at 2030, and must not focus narrowly on only the carbon equivalent. Changes in annual methane emissions have a very strong climate effect; compared to carbon dioxide rising methane emissions greatly accelerate warming as has happened in Ireland. Cutting them would provide a large contribution to meaningful climate action. Methane emissions cannot be supplemented by an equivalent reduction in other GHGs.. Total agricultural methane must be reduced by at least 35% by 2030 and by about 50% by 2050 (in addition to net zero carbon dioxide and nitrous oxide) to align with the 1.5ºC goal. 

One report, two report, three report, four…

Current time-lags in emissions data reporting and a lack of reporting and monitoring on specific emissions are undermining timely and appropriate action. 

1. More frequent and more prompt turnarounds on emissions reporting data is required to assess alignment with carbon budgets.
2. Nitrogen budgeting, monitoring and limiting nitrogen usage (via fertiliser and feeds) in total and by catchment is strongly recommended to limit GHG emissions, ammonia and nitrate pollution.

Emissions Reductions or Accounting Saviours?

The carbon budget programme should reflect actual emissions reductions, and should not form an accounting process that relies heavily on the presumed reduction or sequestration of GHGs through unproven, or otherwise environmentally-damaging methods. 

1. Unproven technologies for methane or nitrous oxide reduction, or carbon dioxide removal, must not be relied on in meeting targets. If included in future carbon budgets for small-scale benefits, specific details on the expected budget impact over time, technology timelines, and investment cost are needed to accurately assess the impact of these technologies.
2. Land use is currently a source, not a sink, of carbon emissions in Ireland. Forest harvest should be limited to 2030 to protect existing carbon storage in standing forest and drained organic soils, as land carbon losses are currently projected to rise until 2035. However, inappropriate forestry should be removed to protect biodiversity and water quality. 
3. Nonetheless, our carbon budgets should place significantly less reliance on ‘Natural carbon sinks’. There is much uncertainty around the long-term storage capability of these methods, particularly in an increasingly volatile climate that has the potential to damage these stores rapidly through, for example, forest fires.

Ultimately, if Ireland is to genuinely make a good faith effort to be consistent with the Paris Agreement, the carbon budgets adopted next month need to be strengthened in a number of ways. The budgets will need to be significantly reduced and account for economy-wide emissions, take stronger up-front action, incorporate Ireland’s historical responsibility for climate change, and focus on actual emissions rather than accounting practices that rely on unproven reduction technologies and fragile and uncertain carbon storage methods. The carbon budgets programme will also need the support of more frequent monitoring and broader reporting on specific emissions to realise meaningful and essential corrective action that is critical to Ireland meeting its climate obligations.


Sinéad Loughran, An Taisce Climate Committee