Executive Summary

An Taisce recognises that the Climate Change Advisory Council (CCAC) prepared the carbon budgets under a difficult timeframe and that the carbon budgets presented so far by it should be regarded as a work in progress. The Climate Act requires the CCAC and Government to comply with its strongest provisions, which requires that carbon budgeting must be consistent with Articles  (the temperature limit goal) of the Paris Agreement – “on the basis of equity” and “best available science”. However, the CCAC’s “Paris Test” falls short of doing so adequately or clearly, and it therefore now falls to the Government to do so and to ensure that the budgets are deliverable and effective.

Overall, An Taisce presents the following policy positions in regard to setting the proposed carbon budgets, relative ambition over time, and the urgent need for faster reporting, assessment and policy response:

1. That the proposed budgets can only be said to comply adequately with the Climate Act’s strong legal requirement for carbon budgeting to be “consistent with” the Paris Agreement Article 2 goal if the CCAC and Government clearly set out reasoning on the basis of equity and best available science, particularly in respect to prudence, historic responsibility, and the treatment of international aviation and shipping emissions.

2. That the proposed carbon budgets require to be reduced and more front-loaded to ensure that the precautionary principle is catered for in achieving at least the CCAC’s recommended carbon budgets to 2030. This is necessary in view of the high risk that the built-in assumptions as regards LULUCF will not be realisable.

3. That the five-year carbon budgets will only be effective in driving climate action if the carbon and nitrogen drivers of emissions are effectively limited. Current reporting is too slow to ensure policies can affect rapid course correction as necessary. It will be crucial to establish a simplified framework of: monthly reporting of key quantities via CSO data; ongoing CCAC or EPA comparison with target carbon budget pathways for CO2, N2O and CH4; and a Government mechanism for rapid-response policy course corrections, if needed, by the responsible Ministers.

Our Consultation submission, specifically addressing the questions to which the Minister welcomes
responses, is structured as follows:

1. The CCAC Technical report accompanying the proposed carbon budget programme.

2. How effort is shared to meet the 51% emissions reduction by 2030 across the first two carbon
budgets, 2021-2025 & 2026-2030.

NOTE: Under the Act, the 51% reduction only relates to the CCAC’s initial provision of the carbon
budgets, so it ceases to be relevant once the five-year carbon budgets are set.

3. The third carbon budget for 2031-2035 being consistent with the national objective for a climate
neutral economy by no later than 2050.

4. Any other observations.

Read An Taisce's full submission to the Public Consultation here: An Taisce Carbon Budgets Submission 2022