Ireland’s carbon budgeting situation is far more pressing than the EPA Projections report has indicated

The EPA 2023 Greenhouse Gas Emission Projections report, released Friday 2 June, states that Ireland’s first two carbon budgets (2021-2030) are projected to be exceeded by a significant margin of between 24% and 34%. Under the Climate Act as amended in 2021, carbon budgets are intended to require Governments to achieve the level of action needed for Ireland to meet its ‘fair share’ climate action commitments under the Paris Agreement of 2015. 

An Taisce’s analysis shows that Ireland's carbon budgeting situation is further off track than the EPA report indicates (see Appendix). The 2021 Climate Act is very clear in its requirement that any overshoot of the first five-year budget (to the end of 2025) must be carried forward to reduce the following five-year budget for 2026–2030 [1]. This critical analysis, which is essential for decision-makers, is missing from the EPA Projections report.  

Emeritus Professor John Sweeney states that:

The reality of the current emissions trajectory toward the end of 2025 means the carbon budget overshoot to be removed from the 2026-30 budget is so significant that it will be much more difficult for the next Government to stay within the legal requirement. This means that highly effective emergency course-correction measures must be immediately enacted by the present Government to limit the overshoot.

The EPA report provides two emissions projection scenarios, called WEM and WAM, respectively based on data for existing and projected additional government policies. These projected emission pathways over time are then compared with the legally binding carbon budgets approved by the Oireachtas. 

In the EPA report, Budget 2 is exceeded by 125 MtCO2eq for WEM and 80 MtCO2eq for WAM. By contrast, in our analysis correcting Budget 2 for prior overshoot, the exceedance  is substantially greater: 170 MtCO2eq or 110% for WEM; and 117 MtCO2eq or 72%, for WAM. 

An Taisce’s revised analysis [2] shows that there is a basic budget maths issue in that the EPA report (Sections 4.1 and 4.2) omits to show the carry-forward of the prior period’s overshoot that under the Act must result in a corresponding reduction in the subsequent carbon budget. 

Separately, all references to a target of “51% reduction by 2030 compared to 2018” and the related indicative Sectoral Emission Ceilings comparisons (Table 1 and 2), are out of date [3]. The percentage reductions required by 2030 will be much greater than 51% even if the most optimistic (WAM) trajectory is followed to 2025, and the Sectoral Emission Ceilings for period 2 will require correction proportionate to the reduced 2026-2030 carbon budget.

An Taisce is writing to the EPA requesting that they clarify the Projections report’s analysis (in sections 4.1 and 4.2) to report on the Climate Act’s requirement to reduce the next carbon budget in line with the current budget overshoot. Such re-analysis clearly implies a need for dramatically increased climate action urgency by the current Government. 

Professor Barry McMullin comments:

In the light of the rapidly widening gap between Irish climate ambition and Irish climate action, now highlighted so clearly by An Taisce, the forthcoming annual revision of the Climate Action Plan (CAP24) must surely incorporate very substantial new measures, in addition to much more robust and accelerated delivery of all of the measures presented in the current Plan (CAP23) across every sector to meet the proportionately reduced Sectoral Emission Ceilings projected for the period 2026-2030. 

Nothing less can plausibly be regarded as good faith engagement by all relevant Ministers with the requirement imposed by the Climate Act (s. 6B.13) that they shall each  “... in so far as practicable, perform his or her functions in a manner consistent with” the carbon budgets applying to any given budget period.

Political accountability for climate targets and timely climate action course corrections are essential to meeting Ireland’s declared carbon budget obligations. It is crucial that the EPA and government departments accurately portray projections and progress relative to carbon budgets, correctly reflecting the Climate Act. 

Even if meeting the legally adopted national carbon budget is not achieved in a particular period, Ireland’s commitment to the Paris Agreement means that radical policies and measures to reduce the use of fossil fuels and nitrogen fertiliser, and to limit timber harvest rates and peat extraction, must still spell out the deepest possible emission reduction pathways for each sector. 

Correcting the budget overshoot currently projected by the EPA may well now require limiting emissions-intensive activity (directly or indirectly) in sectors such as private transport, data centres, intensive agriculture and aviation. Robust, effective, interventions will continue to be required at least until our economy and society can be properly redirected onto a genuinely sustainable trajectory. 

Economic growth or hopes for technical solutions cannot continue to be used as an excuse for failure by Government departments or agencies. Ireland’s commitment to meeting carbon budgets aligned with fair share action and climate reality means that cutting high emissions activities has to happen now, not later. Otherwise we will continue on the current unsustainable path.

It is essential that our carbon budget situation is communicated transparently to ensure that this Government and future ones are accountable for meeting the carbon budgets as set out under the Climate Act. Otherwise, Ireland’s part in the current global slide toward climate catastrophe will continue. 


Contact: Professor John Sweeney, Phone: 0872476516


[1] Climate Act, as amended 2021, Section 6D:

(5) Where the total greenhouse gas emissions for a preceding budget period exceed the carbon budget for that period, the Minister shall carry forward the excess greenhouse gas emissions from the preceding budget period to the current budget period and the current carbon budget shall be decreased by the amount of greenhouse gas emissions that are carried forward.

[2] Appendix: Comparison of EPA projections with the agreed carbon budgets. Tables and charts showing An Taisce’s analysis accounting for carry-forward of prior excess emissions to correct the subsequent budget period.

[3] As per this Written Parliamentary Answer from Minister Ryan in March 2023, the obligations under the Climate Act, as amended 2021, Section 6A(5), relating to a reduction in annual GHG emissions of 51% by 2030 (relative to 2018), applied solely to the deliberations of the Climate Change Advisory Council in proposing the initial budget programme, and those obligations are already “fully met”. Under the Act, the enduring statutory obligation on individual Ministers and the Government as a whole is to ensure compliance with the carbon budgets, as adopted by the Oireachtas, rather than to achieve any particular level of reduction in annual emissions in any single year. To the extent that annual emissions track above what would be required for budget compliance in any given period (as they have done to date), the statutorily required emissions reduction in following years necessarily increases. Specifically, the level of annual emissions reduction required in 2030 is now determined by the carbon budgets, rather than vice versa. The EPA projections analysis and communication entirely fails to present this new statutory reality.