An Taisce has submitted its response (Note 3) to a public consultation, regarding “A discussion document on the potential for Greenhouse Gas mitigation within the Agriculture and Forestry sector”, held by the Department of Agriculture, Food and the Marine (DAFM) (Note 2).

Disappointingly, the DAFM discussion document does not live up to its title. It does not plan for any mitigation of annual agricultural total emissions at all. By definition, mitigation of agricultural emissions means emitting less greenhouse gases.

The assessment of the International Panel on Climate Change states: “Limiting climate change will require substantial and sustained reductions in greenhouse gas emissions”. Therefore, An Taisce strongly urges DAFM to revise the document so that the Mitigation Action Plan does in fact plan action on mitigation.

John Gibbons, of An Taisce’s Climate Change Committee stated:

“Per person, our national emissions are unacceptably high, especially in agriculture and transport. Currently, Ireland is falling woefully short of our 2020 emissions target due to a continual lack of political will to set a new course.

Contrary to the aims of Minister Coveney and the Department of Agriculture, this mitigation discussion document is not ‘climate smart’. It fails to deliver. A revised agricultural mitigation action plan that plans definite action to achieve immediate cuts in annual absolute emissions in agriculture is urgently needed.”

The DAFM discussion document claims that Irish farmers will “have to produce extra food to feed a growing global population while respecting the environmental limits of the planet.” It goes on to state that we should seek to be “the global leader in sustainable food production.”

Unfortunately, climate projections are clear that global emissions from livestock agriculture, like fossil fuel extraction, will likely have to be limited to achieve re-stabilisation of the Earth’s climate system.

Beef production in general is very inefficient with extremely high carbon emissions per kilo. Dairy cattle in Ireland produce 9% more methane emissions per head now than in 1990, so that per head greenhouse gas ‘efficiency’ has in fact decreased in Ireland over the past 25 years.

John Gibbons continued:

“Ireland’s FH2020 and FH2025 policies aim to produce more livestock-derived food to feed a growing global population of wealthier consumers will not respect the environmental limits of the planet or feed the poorest.”

Ireland’s binding 2020 emissions target is to achieve 20% reductions in emissions relative to 2005. Currently, we will only achieve 2%. As Irish agriculture produces nearly a third of national emissions, it is a major part of this national failure to control emissions. Agriculture had steadily reduced emissions until 2011 but the agri-industry’s Food Harvest 2020 plan is rapidly reversing that progress by expanding livestock production.

The DAFM document says this course is not complacent. An Taisce disagrees. Increasing livestock-dominated agriculture and an ever more road-focused transport sector are setting Ireland’s course for climate mitigation failure on a grand scale. We strongly urge a change toward a more sustainable future.

The Department of Public Expenditure and Reform forecast very large costs for emissions target non-compliance after 2020 (Note 4). DAFM’s document says these “will come at a cost to the Irish Exchequer”. Is letting the general taxpayer pay for pollution costs, smart financial policy? This would be another PSO charge for the Government’s failure to plan for the future. Economists, common law and common sense say that the polluter should pay.

John Gibbons continued:

“Why should the Irish Exchequer and Irish citizens pay for emissions caused by the livestock products consumed in other countries?” An Taisce believes that most Irish farmers and citizens sincerely want to act to reduce our collective commitment to climate risk. But, with Food Harvest 2020 and the end of milk quotas, current policy including the Department’s discussion document is setting a course that exposes both ourselves and future generations to ever greater financial and climate risks."

An Taisce urges DAFM and the agricultural sector to plan for and achieve near-term and continuing absolute emission cuts to play a real part in Greenhouse Gas mitigation.


For further information, please call:

John Gibbons, An Taisce Climate Change Committee Tel: +353 87 233 2689
Charles Stanley-Smith, Communications, An Taisce Tel: +353 87 2411995
email: [email protected]
An Taisce The National Trust for Ireland


  1. The current Climate Action and Low Carbon Development Bill provides for the preparation of a national mitigation plan to articulate a national vision for the transition to a low carbon, climate resilient and environmentally sustainable economy over the period to 2050. Each Department is to create its own Mitigation Plan to fit into the overall plan

  2. The Department Of Agriculture, Food and Marine launched a Consultation on its draft Greenhouse Gas Mitigation plan entitled ‘A discussion document on the potential for Greenhouse Gas (GHG) mitigation within the Agriculture and Forestry sector’ it is here

  3. An Taisce’s critical response and submission to this draft is here

  4. DPER (2014) Future expenditure risks associated with climate change / climate finance.

  5. An Taisce believes the DAFM mitigation discussion document:

  • Fails to acknowledge that climate smart science shows that increasing growth trends in global livestock emissions are unsustainable in resource consumption and greatly increasing the risk of ‘dangerous climate change’ of over 2ºC.

  • Plans to increase livestock emissions that will add to Irish responsibility for climate risk

  • Accepts that the general taxpayer will pay the cost of missing emission targets due to the failure of Ministers and the Department of Agriculture

  • Confuses ‘emissions efficiency’ with ‘carbon footprint’, misleading farmers and the public regarding the aim of climate mitigation

  • Takes all of Irish forestry and land use ‘sinks’ for carbon that can compensate for emissions and assigns them only to agriculture. There is no scientific reason for agriculture to be solely allowed this role.

  1. An Taisce propose that a revised Mitigation Action Plan for agriculture needs to:
  • Produce actual cuts in annual total emissions. “Flatlining” emissions is not reducing them.

  • Accept that agriculture should work with other sectors within a National Mitigation Plan to achieve substantial and sustained cuts in absolute emissions, including agricultural emissions.

  • Set out the basis of a substantial and sustained public information campaign stressing the urgency of strong, near-term cuts in GHG emissions in line with science and global equity.

  • Ensure that a planned emission reduction path for agricultural emissions should be separate from any land use sequestration or offsets.

  • Accept a change of course, steadily away from livestock production unless Irish agriculture emissions are definitely displacing emissions elsewhere. This will only be true within an emissions trading scheme and with a price on greenhouse gases.

  • Acknowledge that ‘efficiency’ is not enough – improving 'emission factors' per unit of production is not the same as reducing the total ‘carbon footprint’ of an activity (two terms misleadingly confused by Teagasc and DAFM).

  • Discuss the appropriate price on methane and nitrous oxide pollution, as well as Carbon dioxide, given the likely total resultant climate damage. Such costings are in peer-reviewed literature and should be detailed to enable discussion.

  • Accept and ensure that the end-consumer of food products needs to pay for the emissions costs. Revenues gained can be ringfenced to funding farmers and others who cut emissions.

  • Prioritise research to achieve real year on year cuts in emissions from agricultural land. Teagasc can change course to meet this challenge so that farmers can benefit from carbon credits for moving to low carbon food production, solar and wind energy farming and forestry to sequester carbon. This is the future of climate smart agriculture.

  • Request far stronger cross-government co-ordination of climate policy so that stakeholders and citizens including have far more certainty. We need to know how Ireland’s carbon budget, our remaining quota of carbon emissions to avoid dangerous climate change, will be distributed among sectors and through the coming decades.