An Taisce made this submission to the consultation on the Draft National Energy and Climate Plan (NECP). We endorse the joint briefing submitted by Environmental Justice Network Ireland, Community Law and Mediation, Friends of the Earth and academic experts entitled “Ireland’s Updated National Energy and Climate Plan: Does the draft updated plan show a path to net zero?”, which analyses the deficiencies in the Draft NECP and sets out priority actions for the Department of Environment, Climate and Communications.

The draft updated NECP, which is long overdue, is entirely unfit for purpose. It fails to set out a plan with policies and actions that demonstrably meet Ireland’s carbon budgets to 2025 and 2030 and set us on a clear path to meeting 2050 targets. It lacks up-to-date and complete data as well as emissions reduction pathways and scenarios. It is also not aligned with the National Long Term Strategy, a legal requirement, and fails to demonstrate how Ireland will meet European climate targets and objectives.

The public consultation on the Draft NECP didn't provide for meaningful public engagement, and it came far too late in the development of the updated NECP. The questionnaire provided by the Department of Environment was extremely limited, including by word counts in the only two sections that allow for personalised responses. Additionally, only providing a PDF-based questionnaire that must be filled out electronically and emailed while not providing any facility for the submission of hardcopy responses was inaccessible and did not provide for broad engagement. Moreover, the lack of up-to-date and complete data and scenarios in the Draft didn't allow the public to actually understand and evaluate the updated plan. No explanatory information or accessible copies was provided to facilitate public understanding of the updated Draft.

An Taisce now strongly urges the Department to reconsider the draft updated NECP and to immediately take all of the actions set out in the joint briefing document as referenced above.