The CCAC unveils Ireland's first Carbon Budget Programme | Fieldfisher
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The CCAC unveils Ireland's first Carbon Budget Programme

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The Climate Change Advisory Council ("the CCAC") has presented its proposal for Ireland's first carbon budget programme, with Ireland set to take a significant step towards meeting its key emissions targets if the proposed budgets are approved and adhered to.
 
Established under the Climate Action and Low Carbon Development Act 2015, the CCAC is an independent advisory body tasked with assessing and advising on how Ireland is making the transition to a low carbon, climate resilient and environmentally sustainable economy by 2050.

The advisory council, whose composition includes leading climate scientists and energy experts, has made recommendations for two five-year carbon budgets that will aim to reduce the State's carbon emissions by 51% by 2030. This is the first time Ireland will set limits on greenhouse gas emissions for set periods of time.

What are the carbon budgets?

The carbon budgets represent the total amount of greenhouse gases that may be emitted in the State during a 5-year period, and are set with the view to furthering the objectives of the EU Commission's 2030 Climate Action Plan. The Climate Action and Low Carbon Development (Amendment) Act 2021 ("the Act"), signed into law in July 2021, implements the Climate Action Plan, committing Ireland to reaching a legally-binding target of net-zero emissions no later than 2050, and a cut of 51% by 2030 (compared to 2018 levels).  The Act establishes a system of carbon budgeting, to include three 5-year economy-wide budgets included in each carbon budget programme, with the CCAC recommending the following:
 
  • 2021-2025: Average year on year reduction on carbon emissions to be set at 4.8% with a limit of 295 million tonnes of CO2 equivalent emissions;
  • 2026-2030: Average year on year reduction on carbon emissions to be set at 8.3% with a limit of 200 million tonnes of CO2 equivalent emissions;
  • 2031-2035: The third carbon budget is provisional, with the average year on year reduction on carbon emissions proposed to be set at 3.5% with a limit of 151 million tonnes of CO2 equivalent emissions.
What happens next?

Minister for the Environment, Climate and Communications, Eamon Ryan, will bring the proposed carbon budgets to Government and the Oireachtas will be tasked with reviewing and approving the budgets within a 4-month period. Once these overall economy wide carbon budgets have been approved and adopted by the Oireachtas, the Government will have the challenge of setting out how they will be applied to each sector of the economy, including the most challenging sectors with traditionally high emission levels such as in transport, agriculture, heating, power generation and carbon-intensive industry.

The Government will set out the indicative ranges of emissions applicable to each sector in its Climate Action Plan 2021, set to be published in the coming weeks, with Minister Ryan stating that "there will be different targets for each sector, based on their respective starting points and the relative difficulty, cost, speed and benefits of reducing emissions".

Who will monitor compliance?

The Environmental Protection Agency ("EPA") and the CCAC will produce annual reports to inform monitoring of compliance with national and sectoral progress towards each carbon budget and sectoral emissions ceiling. Ministers will also be obliged to face an Oireachtas Committee to provide an overview on performance in implementing Climate Action Plan actions and adhering to their sectors emissions ceiling under the applicable carbon budget period.

Challenges

The scale of the task at hand has not been overlooked, with a recent report from the EPA highlighting that Ireland only reduced its emissions by 3.6% in 2020, a year in which much of the economy was closed for business. It further underlined the fact that Ireland had only achieved a rate of reduction in emissions of 7% by 2020, despite a commitment to the EU to reduce by 20%.

There is also likely to be pushback in certain sectors, with the Irish Farmers' Association president Tim Cullinan expressing his concern at the proposals by stating that "our most productive farmers simply cannot remain viable with the level of restrictions that are proposed and this will have profound implications for the rural economy". The challenges posed to all sectors in implementing the carbon budgets have been acknowledged by the CCAC, who have highlighted that it will be critically important that the potential for adverse impacts are identified, recognised and addressed, stating "Individuals and communities at risk of employment loss or disproportionate costs need to be identified and assisted in making the transition”.

Nonetheless, while the impact that the proposed carbon budgets will have on society and the economy remains to be seen, the Chair of the Council indicated that they will facilitate action on climate change in "a planned and organised way", noting that the changes required now will only have a real impact on emissions in the second 5 year budgetary period.
 
The Climate Action and Low Carbon Development (Amendment) Act 2021 is available here.

Details on the EU Commission's 2030 Climate Action Plan are available here.

Details on the EPA's Report on Ireland's Provisional Greenhouse Gas Emissions 1990-2020 is available here.

Written by Zoe Richardson, Dena Keane and Iarlaith Connor

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