Submission of the Environmental Pillar...

Submission on the Draft National Mitigation Plan of 36

Submission of the Environmental Pillar on

The Draft National Mitigation Plan

to transition Ireland to a

Low Carbon Economy by 2050

July 2015


Contents

1.0 Introduction 3

2.0 Key Recommendations 4

3.0 Feedback on the Consultation Document 9

4.0 Leadership 13

5.0 Role of Biodiversity in Climate Change

Mitigation

19

6.0 Energy 23

7.0 Agriculture 28

8.0 Transport 31

9.0 Housing 35


1.0 Introduction

The Environmental Pillar welcomes the opportunity to input into the Draft National

Mitigation Plan and looks forward to further input as the plan evolves.

The Environmental Pillar strongly welcomes and supports the Minister’s

commitment to transition to a low carbon future. We anticipate that this will be

implemented in a clear, directional robust national mitigation plan.

The Environmental Pillar highlights the importance of incorporating this plan into all

other, existing and upcoming, national strategies, policies and plans. It is not a

stand-alone policy but one that must underpin all others and cross all Government

Departments.

The Environmental Pillar notes that all mitigation actions in the transition agenda

are cost effective given that there are no jobs on a dead planet.


2.0 Key Recommendations

Leadership

• That the government, both political and administrative, across all parties and

departments, become familiar with the cumulative effect and science behind mitigation

actions.

• That the government recognises its leadership role in the transition process and seeks a

cross party, interdepartmental agreement that politics will not deter implementation of

mitigation plans which may not always be popular.

• That government recognises that they may be held accountable for inaction given that

they have received overwhelming evidence and advice for many years about the need to

take action. In this context they would be well advised to accelerate their efforts now.

Citizen Empowerment

• Lead the transition by facilitating societal awareness. Raise awareness and consult people

on the best courses of action. Do this with national citizen bodies down to regional and

community scale.

• Ongoing awareness raising to complement and support the mitigation actions. Use the

media as would happen with other public interest campaigns such as smoking and road

safety.

• Secure funding to adequately resource community led and community based transition

plans.

• Establish a local transition office in each county to raise awareness, and inform and assist

in the implementation of mitigation plans.

• Resource existing transition actors who already do all of the above.


Coastal Ecosystems

• Incentivise coastal ecosystem protection for biodiversity, flood management and carbon

storage.

• Support the introduction of mechanisms at EU and international level to incentivise the

protection and restoration of coastal ecosystems for their multiple interlinked roles

including sequestering and storing carbon.

• Draft national erosion control and managed retreat policy which takes climate change

mitigation and adaptation into full account. This includes carbon emissions and loss/gain

of sinks as core elements

• Support the drafting and delivery of training modules on coastal and riverine climate

change adaptation and mitigation for engineers and planners, taking latest international

experience into account and incentivise the uptake of in-service training courses for

engineers and planners.

• Maximize supports for conversion to organic methods of production and for sustainable

horticulture

• Wetlands are integral and the Environmental Pillar would like to see full implementation

of Ramsar Wetland convention1 climate change mitigation policy.

Forestry

• Promote agroforestry and protect scrublands

• Develop Forestry and Climate Change guidelines

• A bird/biodiversity forest sensitivity map should be developed to aid in planning.

Peatlands

• That the First National Climate Change Mitigation Plan ensures that the restoration of

peatlands to capture its climate change mitigation potential is included in the First Plan,

quantified and restoration is initiated.

• That adequate funding is assigned to this activity to begin work immediately.

1 climate-l.iisd.org/category/actors/multilateral-environmental.../ramsar/


Biodiversity

• The Environmental Pillar paper entitled ‘Ireland’s Biodiversity: Our natural ally in the fight

against climate change’2 should be considered in its own right for the purpose of this

submission.

Energy

•••• The Environmental Pillar made a detailed submission to the development of the National

Bioenergy Strategy and European policy3 both of which should be considered in parallel

with this submission.

•••• A bias towards community owned projects should be developed. A precedent for this

currently exists, whereby the Commission for Energy Regulation (CER) can direct that a

grid offer be given for ‘innovative’ developments. The definition of ‘innovative’ projects

should be widened to include for community energy projects, thereby facilitating easier

access for community energy projects onto the grid.

•••• Clear and transparent procedures for grid connection should be established for

community energy or small scale projects, with guaranteed connection, and reasonable

connection times, such as the process for micro generation connections. This should

apply to all community energy projects within Gate 4 and future applications.

•••• Clarity should be provided on Feed in Tariff rates for post 2017 when the Renewable

Energy Feed in Tariff (REFIT) scheme expires.

•••• Shift policy priorities from bioenergy to energy efficiency

Fossil Fuels

•••• Phase out fossil fuels and do not consider any fossil fuel exploration in Ireland.

2 ien.ie/files/2014/10/WEB-booklet3.compressed.pdf

3 http://environmentalpillar.ie/pitfalls-and-potentials-the-role-of-bioenergy-in-the-eu-climate-and-energy-policy-post-

2020/


Local Energy Action Plans

•••• Host national, regional and local conversations to design an energy vision as per the NESC

report4

•••• Local Energy Action Plans developed with comprehensive public participation and with

resources available to support the implementation of a subsequent strategy.

•••• A bias towards community owned projects should be developed.

• Environmental Pillar Policy on Community Energy5 contains many suggestions for an

energy transition.

• Environmental Pillar submission6 to Affordable Energy Consultation 27 February 2015

Agriculture

•••• A ‘climate smart’ pathway for agriculture focusing on increased nutritional output while

decreasing total annual emissions from the entire sector.

•••• An ‘economic smart’ pathway for agriculture focusing on land use diversification so as to

ensure our farming community have a resilient livelihood.

•••• According to the IPCC Fifth Assessment Report7 supply-side mitigation options include:

cropland management, grazing land management, restoration of soils, and reduction in

use of high input products (such as production of fertilizers, emissions resulting from fossil

energy use). (Taken from EP submission8)

•••• To understand agriculture and climate comprehensively the Environmental Pillar suggest

consulting the IPCC Agriculture, Forestry and Other Land Use (AFOLU) chapter9

4 www.nesc.ie/en/publications/publications/nesc-reports/wind-energy-in-ireland-building-community-engagement-

and-social-support/ 5 http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/Environmental-Pillar-Community-Energy-Policy-

March-2015.pdf 6 http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/EPAffordable_Energy_Consultation-1.pdf

7 http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_chapter11.pdf

8 http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/Environmental-Pillar-Submission-on-Agriculture-

Roadmap.pdf 9 http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_chapter11.pdf


Transport

•••• Tax carbon at a level where it will encourage the move away from fossil fuels. Sweden

with a CO2 tax of €150 t/CO2 is a good example of a good social protection system, a

competitive industry and decoupling of growth from carbon. 10

•••• Stop subsidising fossil fuel. When unleaded petrol became cheaper than leaded everyone

made the switch. Make electricity the more attractive option.

•••• Improve and incentivise transport options available to the public by encouraging a joined

up transport systems across public and private sectors.

•••• Decarbonise all public transport systems.

•••• A Strategic Framework for Investment in Land Transport must be written in the context

of the climate change challenge and National policy in relation to transition to a low-

carbon economy. - Environmental Pillar submission11

Housing

•••• Massive Investment in retro fitting Home Insulation through “Pay As You Save” scheme.

•••• Continue with and expand the Better Energy Communities scheme, run by the SEAI

Sustainable Energy Authority of Ireland.

•••• The Environmental Pillar proposes that a community energy policy be devised and its

implementation be adequately resourced.

•••• The Environmental Pillar Policy Statement12

on the Flooding Crisis November 2009 outlines many

planning considerations in climate mitigation.

10

http://www.carbonpricingleadership.org/news/2015/5/24/sweden-decoupling-gdp-growth-from-co2-emissions-is-

possible 11

http://environmentalpillar.ie/wp/wp-content/uploads/2015/07/Environmental-Pillar-Submission-to-the-Public-

Consultation-on-Investing-in-our-transport-future-1.pdf 12

http://environmentalpillar.ie/policy-statement-on-the-flooding-crisis-november-2009/


3.0 Feedback on the Consultation document

Despite the consultation being about the process for the development of the NMP - the

consultation document entitled: “Invitation to submit views on the development of Ireland’s first

National Low Carbon Transition & Mitigation Plan” is very much just a background paper, and

contains very little in the way of proposals for consultation.

The department’s consultation webpage in fairness describes it as follows:

“To facilitate this round of stakeholder engagement, a background paper outlining the

process by which the NMP is being developed, and the progress to date, has been

prepared.”

In the main it merely sets out the context and what has happened at a very high level and fails to

detail many specific proposals for consultation on the development of the NMP other than some

high level and superficial analysis of the role of the new Climate Bill, with a mention of some

vaguely specified steering and technical groups, and some very high level and incomplete content

elements for the NMP which “may” or “might” be included in the NMP.

In short this is a very disappointing presentation, and one might have hoped for more mature and

detailed considerations to prompt a robust consultation and consideration of options in relation to

the process of development of the NMP. The Consultation itself while admittedly welcome has

also not been well publicised and occurs over the summer vacation period, and is very late in the

day given the deadlines and imperatives at stake.

The background document also focuses in a very limited and very high level way on four specific

sectors. We submit that consideration should be given to further, if not all sectors and

Departments, and very specifically to Trade and Enterprise given their effect on energy demand

and consumption. Fundamental changes are needed across the board if emissions are to be

reduced in ensuring industry uses all resources more efficiently – as all resources effectively feed

into at some point energy and emissions, either through extraction of their raw materials, their

production, their transport, their use and/or their disposal. Additionally, consumption patterns of

industry and end consumers need to be influenced in terms of choices which have positive or at

least the least negative climate impact. It is not sufficient to assume that management of energy

production in the Energy sector, or Transportation sector will be sufficient to drive these changes.

It is also not clear to what extent Agriculture incorporates Agri-Food, Forestry and Fisheries in

accordance with the Departmental construction, of DAFM.

The consultation document provides no meaningful insight into the proposed process for further

development of the sectoral and national NMPs, or what will be produced and what level of

granularity and consistency checking will be required across plans, nor any practical insight of how

that will be tested and achieved.


Section 10 entitled “Initial outline of the NMP” starts off to create an expectation it will address

meaningfully the content of the NMP’s - but it fails to do so, and simply indicates a list of topics

which the NMPs “may” or “might” include. Section 10 and the rest of the document also clearly

fails to indicate that there will be a set of standardised informational and process requirements

and well maintained and independently verified data sets which will inform any sectoral analysis

which is the fundamental foundation to any plans arising.

Additionally, while it is accepted this is a high level document - there is an absolute failure to even

stipulate the need for the NMP process to explicitly identify problematic patterns of use or

behaviour and target them. For example, in the overview of the Energy sector - the overview fails

to mention energy production through the use of peat. Even at its most simplistic level this is

clearly a practice which we should be specifically stopping in any low-carbon transition strategy

given the positive Carbon Dioxide sequestration effects of our bogs, and the negative effects of

emissions from peat power plants. Yet the overview sections dealing with the Energy sector fail to

address this or similar examples. A systematic current situation analysis of the sectors and what is

happening in them and to what effect from a climate change perspective should be used to inform

the process from the outset. This would ensure that such omissions on what any business analysis

would characterise as “low hanging fruit” or major burdens impacting the sectors overall

performance are not over-looked. It needs to be sufficiently granular to achieve this – as

aggregated emissions values as seems to be what is proposed in the Section 10 which moots

possible content requirements for the NMPs.

In fact it becomes clear when examining Section 10 further that all the NMPs are likely to do is

specify a plan to deliver actions necessary to deliver a further plan:

“Sectoral Action Plans, presenting mitigation actions to meet the 2020 target and the

actions required to mobilise further mitigation actions necessary to achieve the 2030

target and identification of high level objectives beyond this date”

So apart from 2020 targets which we are arguably already challenged in delivering upon – the

NMPs appear from this to be providing only a plan on how to deliver a plan for 2030.

Such delaying tactics are of the most serious concern in the context of the challenge before us and

the 5 year timescales in the Bill for the review of the plans.

The UCC/ESRI Guidance referred to in section 9.4 is caveated as follows: (emphasis added)

“It is important to note that the analysis (December 2013), while presenting least cost

pathways under each scenario, did not address which specific measures would deliver the

transition or how measures would be funded. It is also very important to note that the

purpose of this analysis is to inform further policy development at a particular point in time

and does not constitute Government policy in any way at this point.”

It is entirely unclear how the more granular decisions to select options from these and other

studies are to be assessed and ultimately decided upon in the preparation of the sectoral NMPs.

There is no clarity on, or even discussion on, what criteria and weighting are to be applied in


making the necessary selection decisions. Any purported process to develop an NMP needs to be

clear and entirely transparent on these matters; given these are the factors which will ultimately

determine what the NMPs are to deliver on for the mitigation scenarios identified.

Additionally – simplistic un-caveated suggestions regarding the extension of forestry need to be

more robustly examined – if the process for the development of the NMP isn’t to be characterised

by ‘red-herrings’ or proffered solutions which in fact in certain cases will result in exacerbations of

the situation – such as extensive forestry proposals on bog lands which in fact can serve to release

sequestered carbon. Section 10 in indicating some possible content requirements for the plan –

fails to stipulate the requirement to identify major problems and the basis on which proposals will

be examined and tested on their efficacy in delivering a lower carbon solution. It simply stops

short with a high level specification of “Assessment of the current situation, including emissions

profile”. We can have no confidence that such vague specifications for the content will yield the

necessary focus and results, particularly when there are no headings dealing with “selection

criteria”, “delivery risks” “evaluation of options” etc.

As mentioned earlier in section 9.3 a proposal for a National Mitigation Plan Steering Group and

the High Level Technical Group. In relation to the NMP Steering Group – the profile of the

resources on it is unclear as is their expertise on such matters. There is also a clear absence of any

representation independent of Government on that Group which must be of a concern, as is the

absence of scientific input and consultancy on such a novel process for most Government

politicians and officials as this process is. These proposals need to be revisited.

The High Level Technical Group referred to and its role in relation to the NMP’s and the Steering

Group is unclear – and their focus disconcertingly seems to be restricted to cost efficacy – without

any parameters for the extent of costs to be considered or the timeframes in which those costs

and in particular indirect or consequential costs are incurred. These proposals need to be

overhauled.

Further considerations

Separate to the Climate Bill, there is clearly a lack of focus and prioritisation on climate mitigation

by the current administration. Despite this being the defining challenge of our age – it fails to

inform the action and “the speak” of Government Ministers. This is despite the fact that the

Government has signed off on every IPCC report. For example as recently as Sunday 9th

August on

the Sunday Lunch Time News Programme on RTE Radio One, The Minister for Transport – a sector

critical to Ireland’s climate mitigation failed entirely to once mention Climate Change in the

context of the advocating a transport strategy for Dublin City. It simply isn’t governing the

Government mind-set to the extent necessary.

Additionally, the effect of recent European and international litigation and decisions in particular

on citizen rights in respect of climate change – needs to inform a new approach to fulfilling the


states duty of care to its citizens, their property and the State’s international obligations - in the

preparation, approval and delivery of the NMP, and consideration for a whole range of existing

legislative provisions and rights including and not limited to the European Convention on Human

Rights and the Irish Constitution.

Finally, in relation to the availability of information surrounding this process – the obligations on

government of the Aarhus Convention and the Access to Information on the Environment

Directive must be incorporated into this process and its outcomes. This is of particular significance

regarding the need to weigh any possible restriction against the public interest served by the

proactive and reactive provision of information on this most important of all matter to the public –

Ireland’s response to the defining challenge of our time: Climate Change.

4.0 Leadership


It is vital that we identify leadership as central to the National Mitigation Plan. Cultural, political

and religious leaders around the world are proving a vital link between credible science and the

population at large.

The responsibility and role of government in ensuring we protect the earth’s environment for

future generations cannot be underestimated.

Fundamental to any mitigation plan is an understanding of the cumulative effect. Many people

believe that flat lining or slowly decreasing emissions counts as mitigation. This graphic is to

illustrate the importance of the pathway taken.

A National Mitigation Plan (NMP) will need to plan whole-economy, sustained and substantial13

cuts in total annual emissions. Starting substantive emissions reduction action early is essential to

13

IPCC AR5 WG1 SPM p.19 “Limiting climate change will require substantial and sustained reductions of greenhouse

gas emissions.”


reduce transition costs, avoid unfeasible future rates of decarbonisation, and to limit the extreme

risks of climate change from continued high emissions. With high per capita emissions and GDP,

Ireland has both the responsibility and the capacity to act. An NMP needs to face climate reality.

The remaining future global carbon budget, to give a high likelihood of staying under the 2ºC

limit14

, is rapidly dwindling and is likely to be completely exhausted within 30 years if very rapid

and deep decarbonisation does not occur. Ireland has said it will act in line with this limit, in

accord with science and equity, to constrain its own future carbon budget15

, but to date this is not

happening. Our emissions now and our decisions regarding future emissions reflect either: our

national choice to cut emissions rapidly to help limit climate change; or to continue the current

path of adding significantly to climate change. If reality is faced now, a better future and a

smoother transition to low carbon society are possible.

Any credible National Mitigation Plan needs to set out a carbon-budgeted outline pathway to 2050

aligned with an equitable distribution of the remaining 2ºC global carbon budget. Total CO2 and

non-CO2 emissions (from livestock agriculture) need to decrease. It should identify defined

alternative domestic and international mechanisms to reward emission cuts and penalise excess

emissions relative to a smooth carbon budgeted, 2ºC-aligned pathway, one which respects

burden-sharing within Ireland and globally, and is fair to future generations. If any real mitigation

of total emissions is to be achieved over the next decades the policy pathway planned by the NMP

is very important (see Figure above).

The logical economic response is to regulate a cap, to tax or regulate all greenhouse gas emissions

and then use the revenues to reduce other taxes, ensure that inequality does not increase, and to

fund emission-cutting efforts that respect the environment and communities.

At present the two mechanisms in place for Ireland to cut emissions are: the EU Emissions Trading

Scheme and the domestic Non-ETS 2020 cumulative target for the period 2013 to 2020. Neither

are aligned with the 2ºC target or a globally equable EU carbon budget of future CO2 emissions –

nor are the EU proposed 2030 target and outline 2050 target.

Ireland is far from being on a low carbon pathway16

. A National Mitigation Plan that aims to

decrease total emissions across the whole economy year-on-year is needed this year; we don’t

have time to wait another two years. The Earth’s climate system does not respond to human

economic or political preferences, the sum of the future national carbon budgets will have to be

less than the 2ºC limit if even more dangerous climate change is to be avoided. Leadership based

on the evidence is critical to a safe and smooth transition.

14

IPCC (2013) AR5 WG1 SPM p 27-28: “Cumulative emissions of CO2 largely determine global mean surface warming

by the late 21st century and beyond (see Figure SPM.10). Most aspects of climate change will persist for many

centuries even if emissions of CO2 are stopped. This represents a substantial multi-century climate change

commitment created by past, present and future emissions of CO2.” 15

UNFCCC (2009) Copenhagen Accord, also OECD and other declarations by Ireland and the Taoiseach. 16

EPA (2015) Ireland’s Greenhouse Gas Emission Projections 2014-2035 p14. “Overall it is evident, based on this

analysis, that Ireland is not on track towards decarbonising the economy in the long term”


Furthermore the Environmental Pillar asks that the new Climate Change Advisory Committee be

given the freedom to work in response to science and not be ruled by any short term agenda. They

should be committed to equitable, intergenerational and interspecies justice, ensuring that our

impact on the planet does not threaten the capacity of the planet to support others now and in

the future.

The Climate Change Advisory Committee needs to show real leadership by taking immediate,

honest and meaningful action to tackle GHGs emissions in Ireland. The focus needs to on the root

causes of emissions, the underlying drivers of these, rather than only the pressures or systems -

avoiding the issue by postponing action and/or trying to buy our way out of it is irresponsible.

The government should support actions that will empower all sectors of our economy and society

to reduce emissions rather than supporting inappropriate economic development which typically

undervalues ecosystem processes and threatens the life support functions of our country and

planet.

The national mitigation plan and ensuing projects should be guided by the ecosystem approach17

.

Ecosystem- based management attempts to regulate our use of ecosystems so that we can benefit

from them while at the same time modifying our impacts on them so that the basic ecosystem

functions are preserved.

It is only partly about ecological sciences. It has much do to with gaining an appreciation of the

economic, social and cultural factors affecting the communities concerned with projects. It

recognizes the need for public and community participation at all stages of project development

and implementation. “The ecosystem approach calls for strong stakeholder participation –

involving all those who have an interest in, or could be affected by, decision-making. This is crucial,

not least because the ecosystem approach is about managing human activities. People are much

more likely to act upon a decision and change their behaviour if they understand and accept the

basis on which it was made. This is far more likely with full and active participation.”18

Leadership Recommendations:

17

https://www.cbd.int/ecosystem/ 18

http://www.cbd.int/decision/cop/?id=7148


• That the government, both political and administrative, across all parties and departments,

become familiar with the cumulative effect and science behind mitigation actions. This must

be done right and done now.

• That the government recognises its leadership role in the transition process and seeks a cross

party, interdepartmental agreement that politics will not deter implementation of mitigation

plans which may not always be popular.

• That government recognises that they may be held accountable for inaction given that they

have received overwhelming evidence and advice for many years about the need to take

action. In this context they would be well advised to accelerate their efforts now.


5.0 Citizen empowerment Given the abundance of scientific data, years of education, the recent wave of acknowledgment

from cultural, religious and political leaders there is no doubt that awareness about climate

change is growing and that demand for action will become stronger. There are numerous court-

cases already being taken by citizens, especially younger people, holding their governments

accountable for not fulfilling the states duty of care to its citizens, their health, wellbeing and

property. It is fair to say that inaction, or insufficient action on climate change could be deemed a

breach of human rights.

The public must be in no doubt that climate change and reducing greenhouse gas emissions are

the greatest challenges humanity has ever faced. They must be in no doubt that our government

acknowledges the challenges and that they have adequate plans. Government must prioritise

relaying the fact that the transition to a low carbon future is paramount. Government must

adequately resource awareness-raising and marketing to get the message across. Road deaths and

cigarette health warnings are well advertised but their consequences are minuscule in relation to

the effects of climate change.

The Aarhus Convention protects the public’s right to information and participation in decisions

affecting their environment. It requires the government to proactively provide environmental

information. Climate change is definitely affecting and will continue to affect everyone’s

environment and people will want to be part of the solution, eager to shape the decisions

impacting upon climate. For this they must be well-informed about the enormous consequences

of inaction, alongside the actions they can take together with Government in order to reduce the

danger of runaway climate change.

Government must support mitigation actions citizens undertake. There are many actions that can

be carried out at community level and the current Local Agenda 21 funding scheme goes a little

way towards supporting them. It also leaves the community led actions at the mercy of local

authorities who may not budget adequately for local agenda 21.

Much of the awareness raising around climate change outside of our education system has been

by voluntary groups and NGOs whose work is completely under-resourced. The National Climate

Change Strategy 2007-2012 stated that there was to be a €15m multi-annual Climate Change

Awareness campaign funded from the Environment Fund administered by DECLG but it was

apparently not delivered.

NESC, the National Economic and Social Council recommend Ireland needs a National Energy

Transition Plan that is Intentional, Collaborative and Problem Solving. The Environmental Pillar

supports their recommendations and call upon government to play a central role in ensuring they

are incorporated into policy. In their report19

on community engagement in wind energy in Ireland

19

www.nesc.ie/en/publications/publications/nesc-reports/wind-energy-in-ireland-building-community-engagement-

and-social-support/


the following recommendations are made. They are associated with wind energy for this report,

but relate to community engagement generally in the transition process and they should be

adopted and led by government to facilitate greater public participation in the national mitigation:

1. An overarching energy-transition process that facilitates and guides society-wide efforts to

transform energy systems: An intentional, participatory and problem-solving process

underpins German and Danish experience. An integral component of the process is a national

discussion, informed by international best practice, about how to design an energy strategy in

line with society’s goals.

2. An effective and inclusive process of public participation that helps to shape and share local

value: A genuine and open participatory process for wind energy that brings expertise

together, facilitates exploration and executes possibilities is critical. Communities that

contribute to and shape the local value of energy are more likely to be supportive of future

developments.

3. Enabling organisations, and, in particular, intermediary actors, which support the kind of

problem-solving and entrepreneurship necessary to initiate renewable-energy developments:

Intermediary actors have contributed to the successful development of wind-energy projects

in other countries and in Ireland.

Citizen Empowerment Recommendations:

• Lead the transition by facilitating societal awareness. Raise awareness and consult people on

the best courses of action. Do this with national citizen bodies down to regional and

community scale.

• Ongoing awareness raising to complement and support the mitigation actions. Use the media

as would happen with other public interest campaigns such as smoking and road safety.

• Secure funding to adequately resource community led and community based transition plans.

Establish a local transition office in each county to raise awareness, and inform and assist in

the implementation of mitigation plans. There are numerous similar bodies for similar

national actions such as enterprise and health.

• Resource existing transition actors who already do all of the above. Numerous national NGOs

within the environmental sector have been the main voices in the climate and transition

process but have had their resources slashed at a time when we need them most. The

Transition Network20

was conceived in Ireland, is an international success, has thousands of

projects globally and initiatives throughout the Island. Transition Ireland and Northern

Ireland would accelerate the pace of Ireland’s national transition if it were adequately

supported by government.

20

http://www.transitionnetwork.org


The Role of Biodiversity in Climate Change Mitigation

Protect and restore Ireland’s biodiversity The Environmental Pillar report entitled ‘Ireland’s Biodiversity: Our natural ally in the fight

against climate change’21

outlines how protecting natural habitats is an important and cost

effective option for government to store carbon and offset greenhouse gas emissions.

The report discusses the interdependency of climate, biodiversity and ecosystem services and

shows how integrated policies can achieve climate mitigation and adaptation and at the same

time prevent further biodiversity loss.

It highlights the most urgent Irish policy issues that need to be addressed in order to mitigate and

adapt to climate change without further degrading ecosystem services.

The report covers topics such as peatlands, tree cover, bioenergy, wind energy, coasts, invasive

species, food security, and ecological networks.

This chapter contains relevant information and recommendations however the report should also

be noted in its own right for mitigation planning.

Peatlands- Carbon storage, sequestration and biodiversity co-benefits Ireland’s Sixth National Communication under the UNFCCC states that “Approximately 17-20% of

lands in Ireland are peatlands. It is estimated that these lands contain between 53-62% of the total

soil carbon stock” and “it is estimated that at least 74% of these lands exist in a degraded

condition, with some estimates of greater than 90%”(DECLG, 201322

). In Ireland peatlands

included both Active and Degraded Raised Bogs, Blanket Bog, Wet Heath and fens (DAHG 201423

).

The focus of the First National Climate Change Mitigation Plan is on electricity generation, built

environment, transport and agriculture. Peatlands as a ‘land use’ must be included as there is a

significant body of work which needs to be done to capture the mitigation potential of this land

use and the sooner this starts the better. Peatland restoration will not only help with climate

change mitigation but will also provide co-benefits for biodiversity and help Ireland meet its

international obligations to protect species under the Birds and Habitats Directives and the

Convention on Biodiversity.

Healthy peat bogs store Carbon

21

ien.ie/files/2014/10/WEB-booklet3.compressed.pdf 22

DECLG (2013) Ireland’s Sixth National Communication under the United Nations Framework Convention on Climate

Change (online) available at:

http://unfccc.int/files/national_reports/annex_i_natcom/submitted_natcom/application/pdf/nc6_br1_ire.pdf

[accessed 24/7/2015] 23

DAHG (2014) Draft National Peatlands Strategy (unpublished), Dublin.


Peat bogs store huge quantities of carbon and healthy and intact peat bogs remove carbon from

the atmosphere by actively absorbing atmospheric carbon as peat grows. Globally, peatlands

store more carbon than the world’s rainforests. However, this valuable function is reversed when

peatlands are damaged or drained, with degraded peatlands releasing stored carbon as carbon

dioxide in to the atmosphere and thus adding to greenhouse gas emissions and climate change. In

Ireland, near intact peatlands may actively sequester, on average, 57,402 tonnes of carbon per

year (Renou-Wilson 201124

). However, due to the damaged nature of most Irish peatlands, they

are a large net source of carbon, estimated currently at around 2.64 million tonnes of carbon per

year (Renou-Wilson 2011). This is equivalent to the emissions from more than one million Irish

households per year. Damage occurs through burning, overgrazing, turf cutting and drainage for

conversion to other land uses.

Keeping peat wet

Conservation and management of peatlands is a pressing priority for mitigating against climate

change. The key management objective for climate change considerations is to keep peatlands

wet – peat is formed because of wet conditions and when the peat dries out it begins to

decompose, releasing greenhouse gasses. Drainage, peat extraction, afforestation and other

activities which lower the water table act against the ability of peat to counter climate change.

According to Achim Steiner, UN Undersecretary General, “restoration of peatlands is low hanging

fruit, and among the most cost effective options for mitigating climate change”. This was officially

recognised in 2010 when rewetting of drained peatlands and organic soils as a climate mitigation

action was fully recognised by the UNFCCC. If Ireland is to meaningfully reduce carbon emissions,

then in the first instance and as a priority, significant effort should be concentrated on restoring

or capping the carbon loss from peatland. This will be far more effective than focusing on

increasing the production of bio fuels, for example, or attempting to offset with forestry.

Peatland Restoration

Peatland restoration techniques have been trialled and developed in Ireland and other countries.

The Environmental Protection Agency has commissioned several pieces of research on the

mitigation potential of peatlands and the results of this research need to be built upon.

The draft National Peatland Strategy proposes several actions for the conservation and restoration

of peatlands. These actions not only identify the biodiversity benefits of restoring peatlands but

are based soundly on the need to reduce the climate change impact of degraded peatlands and to

attain the sequestration benefits of restored peatlands. These actions and the research

supporting them should be included in the preparation of the National Mitigation Plan with the

view to initiating restoration of our national peatland resources to mitigate against climate

change. Restoration should include both designated and non-designated peatlands.

Ireland is obligated under the Habitats Directive not only to maintain, but also to restore to

favourable conservation status, the protected habitats listed in Annex 1, including all natural

peatland types and also degraded raised bogs. This is of critical importance as it has already been

24

Renou-Wilson et al. (2011); ‘BOGLAND: Sustainable Management of Peatlands in Ireland’ EPA: Dublin


demonstrated that Ireland has lost 25% of its area of ‘active raised’ bog habitat between the

period 1995 and 2005.25

Peatland Protection-Biodiversity Co-Benefits

Peatlands support rare and threatened species with exceptional adaptation and the loss (and

ongoing degradation) of Irish peatlands equates to a loss of biodiversity at regional, national and

international levels. (Renou-Wilson et al 2011).

Raised bog habitats are important for a number of very rare and threatened birds in Ireland. Like

upland blanket bogs and Atlantic blanket bogs (covered in the Action Plan for Upland Birds in

Ireland 2011-202026

), raised bogs were once far more extensive than today and many birds have

adapted to this environment. Some birds in this group traditionally associated with peatlands,

such as the Curlew and the Greenland White-fronted Goose (also known as the bog goose), have

had to re-adapt to new environments, as many bog habitats have disappeared (Ruttledge &

Ogilvie 197927

). The long-term suitability of alternative habitats is unknown. However, the loss of

bog habitat has also coincided with declines in these species, and while it cannot be said with

certainty that this is the primary cause, changing land management and habitat loss are almost

certainly having a significant impact. Raised bogs provide breeding habitat for two of Ireland’s

rarest raptors the Merlin and the Short Eared Owl, as well as some of the our most threatened

waders including the Curlew, an iconic species which is in danger of extinction with an 80% decline

in numbers (one of the key findings of the Bird Atlas 2007-2011). Similarly upland Blanket Bog also

supports a wide range of bird species and biodiversity which would benefit from restoration.

BirdWatch Ireland has developed Group Species Action Plans for the protection of birds in raised

and blanket bogs. These are An Action Plan for Raised Bog Birds In Ireland 2011-202028

, and the

Action Plan Upland Birds 2011-2020 including blanket Bog.

Restoration of designated and non-designated raised and blanket bog could be a positive

contribution to the protection of birds of these habitats.

Recommendations:


peatlands, to capture their climate change mitigation potential, is included in the First Plan,



25

(Fernandez Valverde et al. 2005 in Wilson, D et al (2013)). 26

Action Plan Upland Birds 2011-2020 27 Ruttledge, R.F & Ogilvie, M.A. (1979) The past and present status of the Greenland White-

fronted Goose in Ireland and Britain. Irish Birds 3: 293-363. 28

An Action Plan for Raised Bog Birds In Ireland 2011-2020


Coastal Ecosystems recommendations:

• Incentivise coastal ecosystem protection for biodiversity, flood management and carbon

storage.

• Support the introduction of mechanisms at EU and international level to incentivise the

protection and restoration of coastal ecosystems for their multiple interlinked roles including

sequestering and storing carbon.

• Draft national erosion control and managed retreat policy which takes climate change

mitigation and adaptation into full account. This includes carbon emissions and loss/gain of

sinks as core elements

• Support the drafting and delivery of training modules on coastal and riverine climate change

adaptation and mitigation for engineers and planners, taking latest international experience

into account and incentivise the uptake of in-service training courses for engineers and

planners.

• Maximize supports for conversion to organic methods of production and for sustainable

horticulture

• Wetlands are integral and the Environmental Pillar would like to see full implementation of

Ramsar Wetland convention29

climate change mitigation policy.

Forestry recommendations:

• Promote agroforestry and protect scrublands

• Develop Forestry and Climate Change guidelines

• These guidelines would maximise the contribution of forestry to climate change mitigation

and ensure that both existing and new forestry is planned and managed to mitigate and

adapt to climate change. Additional afforestation needs to be in the right place.

Afforestation has been identified as one of the causes for the decline in heath habitats

(NPWS 2013, Article 17 report) including wet heath which based on peat. Additionally,

research on the impacts of forestry on bird populations is currently being prepared in

University College Cork and will need to be taken into account. We are concerned with the

potential that marginal land (e.g. upland habitats, scrub, wet grasslands, semi-natural

grassland), which has been the last refuge for biodiversity in an intensely farmed landscape,

will become the focus of afforestation plans.

• A bird/biodiversity forest sensitivity map should be developed to aid in planning.

29

climate-l.iisd.org/category/actors/multilateral-environmental.../ramsar/


• Shift policy priorities from bioenergy to energy efficiency

Peatland Recommendations:


peatlands to capture its climate change mitigation potential is included in the First Plan,



Biodiversity Recommendations:

• The Environmental Pillar booklet entitled ‘Ireland’s Biodiversity: Our natural ally in the fight

against climate change’30

should be considered in its own right for the purpose of this

submission.

30

ien.ie/files/2014/10/WEB-booklet3.compressed.pdf


6.0 Energy Ireland has an obligation to generate 16% of its gross energy consumption from renewable

resources by 2020. After 2020 our renewable obligations will increase. In 2013 only 7.8% of our

energy was generated from renewable sources31

, and a significant amount of this was renewable

electricity from wind. In addition, the recently announced EU ambition to improve energy

efficiency to 30% by 2030 presents significant new challenges to national energy policy. This

considerable challenge of achieving 30% energy efficiency by 2030 will require a faster, wider and

more inclusive national energy policy, which will necessitate active citizen and community

participation to implement our strategic energy goals.

Community engagement

In order to transition to a low carbon future, communities need to be allowed to take up a central

role, to stand behind and embrace the development of the renewable energy projects that are

appropriate to their areas. Community owned renewable energy developments have the

potential to stimulate investment in, and facilitate the growth of, a positive and productive

renewable energy sector. This would have positive support from communities rather than

resistance in both rural and urban locations.

An analysis of our progress towards meeting our EU 2020 greenhouse gas emissions targets by the

Environmental Protection Agency (EPA)32

suggests meeting our 2020 targets will be extremely

difficult. Encouraging community ownership of renewable energy will have a positive impact on

and increase renewable energy development, which will contribute to meeting our EU 2020

targets, 2030 targets and beyond.

Energy Recommendations:

•••• A bias towards community owned projects should be developed. A precedent for this currently

exists, whereby the Commission for Energy Regulation (CER) can direct that a grid offer be given

for ‘innovative’ developments. The definition of ‘innovative’ projects should be widened to

include for community energy projects, thereby facilitating easier access for community energy

projects onto the grid.

•••• Clear and transparent procedures for grid connection should be established for community

energy or small scale projects, with guaranteed connection, and reasonable connection times,

such as the process for micro generation connections. This should apply to all community energy

projects within Gate 4 and future applications.

There is no guaranteed Feed in Tariff offered for generating electricity and exporting it to the grid.

As a result our solar electricity resource is vastly underused. There is great potential for

community solar energy projects and CHP fed with renewable resources to develop in urban and

rural areas. In Ireland renewable energy generation in urban areas is extremely small scale.

31

Sustainable Energy Authority of Ireland (2014) Energy in Ireland, 1990-2013 32

Environmental Protection Agency (2014) Ireland’s Greenhouse gas emissions projections 2013 – 2030


Recommendations: • Clarity should be provided on Feed in Tariff rates for post 2017 when the Renewable Energy Feed

in Tariff (REFIT) scheme expires.

Fair and secure payments to support community energy, micro-generation and auto generation, at

a price that balances the long term socioeconomic costs of this generation (including reduction in

transmission losses, the long term costs33

of CO2 and the balance of trade improvements) with the

total net metering price and ensures the Public Service Obligations (PSO) levy is maintained at

close to current levels.

There is currently no national strategy for community energy in Ireland. National energy policy34

gives little more than passing regard to the potential of community energy, and provides no clear

policy steer to support the community energy industry and increase the number of community

energy projects, groups, partnerships.

Recommendations:

Local Energy Action Plans

• There is currently no requirement for Local Authorities to develop plans on how energy in

their areas will be generated, distributed and used. While a number of Local Authorities

have developed Local Authority Renewable Energy Action Strategies (LAREAS) to identify

zones or areas for renewable energy developments, not all Local Authorities have prepared

such a strategy. Clare County Council’s Renewable Energy Strategy 2014-2020 is a good

example of a local renewable energy strategy35

. It provides an analysis of the energy profile

of the county and a list of strategic aims for the county within each renewable energy

technology.

• Local Energy Actions plans should be developed by each Local Authority, to guide local

energy planning within the Local Authority Area. Thus with the context of National Policy,

local perspectives on energy matters can be provided. It is important that urban areas are

also supported in renewable energy developments, and included within local area planning

as target areas for generation.

• These plans should be developed with comprehensive public participation and with

resources available to support the implementation of a subsequent strategy. This does not

necessarily mean that the government must fund all measures but it should definitely play a

central role in establishing an implementation working group with both statutory and non-

statutory members. Bodies such as the Tipperary Energy Agency36

are well placed to shape

and deliver local plans.

33

The Department of Public Expenditure and Reform estimates the cost of carbon post 2015 as €39/tCO2 e (2009)

http://www.per.gov.ie/reports/ . In the UK the Department of Energy and Climate Change estimates the price of

carbon in £70/tCO2e in 2030 and in £200/tCO2e https://www.gov.uk/government/collections/carbon-valuation--2 34

The National Renewable Energy Action Plan, The National Energy Efficiency Action Plan, Government White Paper,

Delivering a Sustainable Future for Ireland. 35

Clare County Council Renewable Energy Strategy 2014-2020 http://www.clarecoco.ie/planning/planning-

strategy/renewable-energy-strategy-2014-2020/ 36

http://tea.ie


Bioenergy, including biofuels

Bioenergy will play a central role in renewable energy supply.

The national mitigation plan must recognise some inconvenient truths, including

▪ bioenergy is not carbon neutral and some is as bad as or worse than fossil fuels;

▪ much bioenergy is unsustainable;

▪ much bioenergy risks worsening food insecurity in developing countries;

▪ there is an inherent limit to the global sustainable bioenergy harvest.

Recognising these facts, bioenergy which is sustainable both in quality and quantity has a role in

the Mitigation Plan.

Unfortunately, we are still waiting for the Strategic Environmental Assessment of the draft

Strategy which we have been assured will address the issues we raised; they are not addressed in

the draft Strategy itself.

End fossil fuel exploration

We need to end investment in fossil fuel as proposed in the Environmental Pillar submission to the

National Energy Policy Green Paper 201437

Recommendation on Fossil Fuels • A moratorium on fossil fuel exploration should be instigated, in line with the recommendations

contained within the recent IPCC reports, which explain that to prevent runaway climate

change globally over 60 % of fossil fuels need to remain in the ground. New exploration is

contradictory to this advice.

Fracking

Taken from the Environmental Pillar Policy on Shale Gas, Shale Oil, Coal Bed Methane and

‘Fracking’38

In order to limit global warming below 1.5 degrees Celsius, and thereby prevent dangerous climate

change, fossil fuels must be phased out as quickly as possible. We believe renewable energy,

energy savings and a significant reduction of CO2 emissions provide the only viable path to an

environmentally sustainable and healthy future. Exploiting unconventional fossil fuels such as

shale gas, shale oil and coal bed methane will increase total greenhouse gas emissions since

further development of these fuels will increase the world’s dependency on fossil fuels and

consequently slow down the large-scale deployment of clean energy renewables and energy

savings.

37

environmentalpillar.org/wp/wp-content/uploads/2014/08/environmental-pillar-submission-on-the-green-paper-

on-energy-july-2014.pdf 38

http://environmentalpillar.ie/wp/wp-content/uploads/2012/08/Environmental-Pillar-Policy-on-Shale-Gas-Shale-Oil-

Fracking.pdf


Energy Vision

We need a national vision for our energy transition as proposed in the Environmental Pillar

submission to the National Energy Policy Green Paper 201439

• The White Paper should define a vision for Ireland’s Future energy which provides an

overarching framework within which decisions on energy policy are made. Given the risk of

runaway climate change, this vision should define a future system that is no longer dependent

on climate polluting fossil fuels, but rather operates with clean renewable indigenous

resources and with energy conservation at its core.

This complements the NESC proposal that we need a National Energy Transition Plan that is

Intentional, Collaborative and Problem Solving40

.

Energy Recommendations summary:

•••• Phase out fossil fuels and do not consider any fossil fuel exploration in Ireland.

•••• Host national, regional and local conversations to design an energy vision as per

the NESC report41

• The Environmental Pillar made a detailed submission to the development of the National

Bioenergy Strategy and European policy42

both of which should be considered in parallel

with this submission.

•••• Local Energy Action Plans developed with comprehensive public participation and with

resources available to support the implementation of a subsequent strategy.

•••• A bias towards community owned projects should be developed.

• Environmental Pillar Policy on Community Energy43

contains many suggestions for an energy

transition.

•

• Environmental Pillar submission44

to Affordable Energy Consultation 27 February 2015

39

environmentalpillar.org/wp/wp-content/uploads/2014/08/environmental-pillar-submission-on-the-green-paper-

on-energy-july-2014.pdf 40


and-social-support/ 41


and-social-support/ 42

http://environmentalpillar.ie/pitfalls-and-potentials-the-role-of-bioenergy-in-the-eu-climate-and-energy-policy-

post-2020/ 43

http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/Environmental-Pillar-Community-Energy-Policy-

March-2015.pdf 44

http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/EPAffordable_Energy_Consultation-1.pdf


7.0 Agriculture

For the National Policy Position sectoral group of electricity generation, built environment and

transport sectors (abbreviated below as EBT) analysis indicates that already, as of 2015,

achieving the NPP’s target for the EBT sector would require annual emission decreases of 4.7%

year on year up to 205045

.

However, the EPA projections, based on current policies, this EBT collection of sectors will increase

emissions by 20% up to 2035 with increases in transport and energy. If that occurred then

emission reductions of 9% per year would be needed to achieve the NPP target if a new peak is

delayed until 2035 as per the projections.

Meanwhile agriculture gets, in effect, a “free ride”.

The EPA projection to 2035 indicates that agriculture emissions will rise by a few percent and

Teagasc forecast that no emissions reductions will be achieved by agriculture even up to 2050 (see

Figure 10). Agriculture in Ireland is dominated by cattle production for beef and dairy causing very

large GHG emissions. The carbon intensity of dairy cattle has increased due to more methane and

more fertilizer per head as production has increased.

Figure 10: Teagasc figure showing that agricultural emissions are not forecast to decrease at all before

2050. How is this a path to carbon neutral agriculture in Ireland?

45

An Taisce (2015) Submission to the draft National Mitigation Plan consultation


Government isattempting to claim that livestock agriculture is important for global food security

(it is not), that its emissions can be offset by forestry (these offsets are also needed by other

sectors), and carbon leakage of production to less efficient producers is likely (not a valid

argument unless Irish production is brought within a capped emission +2ºC aligned system so that

efficiencies can be realised).

DAFM state46: The FAPRI-Ireland models shows that emissions would raise in the short to

medium term, reaching about 22 MtCO2eq by 2030, and continue to rise at a much lower rate

beyond 2030. The principal divers for the increase in emissions in the short to medium term are

the growing population of dairy cows, pigs and poultry and associated increases in fertiliser

emissions and emissions associated with animal waste. This overall growth in emissions would

be only partially offset by a decline in the number of suckler cows.

In other words, the Department of Agriculture’s discussion document on potential GHG mitigation

within the Agriculture and Forestry sector plans to deliver no mitigation at all. In fact emissions

will increase. Under Food Wise 2025, even suckler cows will not decrease, raising emissions still

further. For climate policy, Food Wise 2025 is extremely unwise.

Mitigation options in ruminants (cattle and sheep) are severely limited so the only possibility for

substantial emissions decrease is a cut in animal numbers47

. This policy option has been rejected

without any substantive societal discussion as to how this refusal to countenance cuts in

agricultural emissions affects the carbon budget of the National Mitigation Plan.

An Taisce’s analysis suggests that if agriculture is allowed to continue with zero mitigation (or in

fact increased emissions as projected under current policy), and the EPA projected emissions

occur in all sectors to 2035, then the EBT sector will have to be zero carbon by 2050 (meaning no

emissions at all from energy, buildings or transport) to achieve an overall cut of 80% in total EBT

emissions by 2050.

This is clearly unfeasible. If the EPA 2035 projection for EBT occurred (a 20% increase relative to

current EBT emissions then there would be almost no carbon budget left for EBT after 2035 to

meet the EU 2050 target. Even on its own terms then (falling far short of a +2ºC outcome) the NPP

makes no sense in regard to the 2050 EU target or in regard to achievability – unless rapid,

sustained action starts now.

Is this an outlook accepted or planned for by the Departments of Energy and Transport?

The disparity between agriculture and other sectors appears to be purely a political decision

favouring food producers and the largest farmers. Ireland’s livestock agriculture cannot

contribute to climate mitigation unless it is part of an enforced cap on emissions. In theory it

already is within such a cap as part of Ireland’s legally binding Non-ETS emissions sector cap and

will be again up to 2030. However, the current plan is that the polluters, the consumers of high

GHG agricultural products will not pay; the plan is instead that general taxpayers will, by reducing

46

DAFM (2015) Discussion document on potential GHG mitigation within the Agriculture and Forestry sector, p60 47

Ripple et al (2014) Ruminants, climate change and climate policy


spending on other services.

The Environmental Pillar made a submission48

to the Department of Agriculture, Food and the

Marine’s discussion document on the potential for Greenhouse Gas (GHG) mitigation within the

Agriculture and Forestry Sector in March 2015. This document is vital reading when considering a

national mitigation plan and should be considered part of this submission.

Environmental Pillar Submission49

to the Public Consultation on the SEA for the Draft Forestry

Programme 2014-2020 and its SEA – 13th Oct 2014

Agriculture Recommendations Summary

•••• A ‘climate smart’ pathway for agriculture focusing on increased nutritional output while

decreasing total annual emissions from the entire sector.

•••• An ‘economic smart’ pathway for agriculture focusing on land use diversification so as to

ensure our farming community have a resilient livelihood.

•••• According to the IPCC Fifth Assessment Report50

supply-side mitigation options include:

cropland management, grazing land management, restoration of soils, and reduction in use of

high input products (such as production of fertilizers, emissions resulting from fossil energy

use). (Taken from EP submission51

)

•••• To understand agriculture and climate comprehensively the Environmental Pillar suggest

consulting the IPCC Agriculture, Forestry and Other Land Use (AFOLU) chapter52

48

http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/Environmental-Pillar-Submission-on-Agriculture-

Roadmap.pdf 49

http://environmentalpillar.ie/draft-forestry-programme-2014-2020/ 50

http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_chapter11.pdf 51

http://environmentalpillar.ie/wp/wp-content/uploads/2015/03/Environmental-Pillar-Submission-on-Agriculture-

Roadmap.pdf 52

http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_chapter11.pdf


8.0 Transport

To meet the EU long-term targets to reduce transport’s greenhouse gas (GHG) emissions, action

will be needed to reduce the carbon intensity of the fuels consumed, to improve the energy

efficiency of transport vehicles, to drive a modal shift and to improve the efficiency of the overall

transport system. The EU White Paper for Transport – ‘Towards a competitive and resource

efficient transport system’ (COM (2011)144) sought to dramatically reduce Europe's dependence

on imported oil and sets the goal of cutting carbon emissions in transport by 60% by 2050

(compared to 1990 levels). There is an increasing urgency to focus on decarbonising Ireland’s

transport sector. This reflects the reality that, despite policies in place to increase efficiency and

reduce GHG emission growth, the transport sector has made limited progress in reducing its GHG

emissions.

Ireland spent €3.5 billion importing fossil fuels for transport last year, accounting for over half of

Ireland’s total energy import bill, according to the SEAI report ‘Energy in Transport 2014’53

.

Ireland’s transport energy consumption per capita is the fifth highest in the Europe, 30% above

the EU average. Against that backdrop, Ireland needs to wean itself off its reliance on imported

fossil fuels which come at prices outside our control, with risks of disruption to supply and of

course with associated harmful emissions.

Environmental taxation already has widespread application in Ireland. The success that followed

the introduction of the plastic bag levy and the progressive car tax system (based on GHG

emissions) has shown the huge potential for taxes and levies to nudge behavioural change away

from environmentally destructive behaviour. To date the former has raised nearly €200 million for

work on the environment, whilst reducing plastic bag use dramatically by 90%. The car tax system

saw a drop in average carbon dioxide emissions from newly purchased private cars of 21%

between 2007 and 2013. Ireland now has the 6th

lowest carbon dioxide emissions from new cars in

Europe last year. Ireland coming sixth is a reflection of the tax choices we make, if we were to

encourage more electric cars onto the road we'd rank higher and have a cleaner environment.

Electrification of Ireland’s Transport Fleet

There are five reasons why Ireland should now choose to accelerate the transition toward

sustainable electric transport or e-mobility:

1. Environment: Electrification is the only credible option left for deep decarbonisation of surface

transport. Electricity is now already a significantly cleaner power source than oil, and will

become more so in coming decades. In recent years around 90% of additional electricity

generation capacity has consisted of wind power. Sustainable e-mobility can help clean up

electricity by providing a storage option, stabilising the grid. In contrast, much of the oil

industry’s investment goes into ever riskier and/or higher carbon ventures such as deep sea

drilling, Arctic oil and oil from unconventional sources, such as tar sands;

2. Energy concerns: Electric traction is inherently more energy efficient than other options. And

from an energy diversity and dependence perspective, electricity is superior to oil, gas or

53

http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Transport/Energy-in-Transport-2014-report.pdf


biofuels that are largely imported. It can draw from a wide variety of energy sources, with an

unmatched potential for domestic production, especially from wind, solar and AD;

3. Alternatives have lost credibility: Natural gas is not as low a carbon solution as once thought

and now seems a less astute choice from an energy security perspective. Biofuels have huge

and, as yet unresolved, sustainability challenges, especially if agricultural land – increasingly a

scarce resource – has to be used to grow them. They are unlikely to provide more than a niche

solution in the sectors most difficult to decarbonise. Hydrogen may be part of future e-

mobility but efficiency issues have yet to be addressed.

4. Trends: E-mobility can reinforce trends towards sustainable transport. The economics of

electric vehicles – high fixed costs, low variable costs – help vehicle sharing. Electrification also

includes a push for more attractive rail. Thirdly, electric traction is well suited for small and

light vehicles such as e-bikes, e-scooters, and small quadricycles that are quickly becoming

more popular;

5. Innovation and competitiveness: Ireland is falling behind in the global race to electrified

transport with Japan and Korea in the lead, Europe and China catching up quickly and the US

investing heavily. These countries are choosing petrol hybrid, plug-in and, ultimately, full

electric vehicles for future vehicles.

A shift to electrification of transport is a bold and appealing vision for transport in Ireland, moving

away from polluting, imported oil to clean indigenously-generated electricity and, in the process,

stimulating jobs, growth and sustainable mobility choices.

Integrated Transport and Increased Cycling Lanes

Irish cities in particular Dublin have expanded massively over the last generation into sprawling

low density cities. It is critical therefore that we deploy our investment as widely as possible and

to provide an integrated network. The proposed projects in the National Transport Authority

Dublin Implementation plan to 201854

i deserve government support. This includes three Bus Rapid

Transit services along five radial corridors along with the running of DART services from Kildare to

Grand Canal Dock via the existing Phoenix Park Tunnel. These projects can integrate all Dublin's

transport services in the short-term. It’s imperative that the Government fund these projects and

deliver them.

There are a number of national rail routes that require integration, particularly a North/South rail

link that would run a through service from Belfast - Swords - Airport - Liffey Junction -

Islandbridge/Heuston - Limerick - Cork. This route would have the effect of integrating transport

across Dublin and Ireland. Provision of such a service would also encourage people to travel by rail

and would have massive tourism benefits. The environmental benefits cannot be understated

either.

More Cycle Lanes

We need more cycle routes in all our major cities and towns, this will have the triple effect of

providing our increasing number of cyclists with a better and safer cycling experience, see less

people using cars, and enhance tourism for Ireland as a whole.

54

http://www.nationaltransport.ie/wp-content/uploads/2011/12/Integrated_Implementation_2013-2018.pdf


Rural Ireland

There is scope for a more integrated transport service in rural areas. Where numerous private and

public providers operate more should be done to link all services including shared timetables,

more park and ride options at non state interest, public transport depots.

Private services are forced to operate from venues away from the public transport depots. The

fact that private services exist indicate that the public service is inadequate or inaccessible on

some level. Collaboration and communication are vital in addressing climate change and transport

providers need to do both if they are to succeed in taking people out of their cars.

Diesel cars

Of all new cars bought in 2013, 73% were diesel. This is a complete turnaround from 2007 when

just 28% were diesel. Here are some facts on diesel cars

1. A typical diesel car emits 10 times more nitrogen oxides than an equivalent petrol car. Testing

conducted by the independent International Council on Clean Transportation (ICCT)55

found a

typical modern Euro 6 diesel emits 7-10 times more nitrogen dioxides (NOx) on the road than

the Euro 6 limit achieved in tests (80mg/km).

2. 12 out of 13 Euro 6 diesel cars failed to achieve the Euro 6 limit in tests conducted on the road.

3. Diesel exhaust fumes cause cancer. Nitrogen dioxide causes a range of short-term health

effects, like asthma; and longer-term effects that shorten lifetimes. In the air nitrogen oxides

are converted into other harmful pollutants like fine particles and ozone.

4. The current system for testing cars in a laboratory is obsolete and produces meaningless

results – the figures quoted by European Automobile Manufacturers' Association (ACEA). The

car industry is fighting to delay and weaken new on-road tests precisely because Euro 6 cars

cannot achieve the limits set.

5. On average, diesel cars actually emit more, not less CO2, than petrol or hybrid cars. The

Society of Motor Manufacturers & Traders (SMMT) figures show that in 2013 the average

diesel car emitted 129.2g/km of CO2. The average gasoline emitted 128.8g/km and the

average alternatively-fuelled car (mainly hybrids) 95.5g/km. Diesel cars also tend to be driven

much further. Over its lifetime a typical diesel drives 230,000km and a gasoline car 169,000km

– all these additional miles produce more CO2. Diesels also cause higher emissions in their

production as they tend to be larger.

According to the IMF, phasing out fossil fuel subsidies could reduce global greenhouse gas

emissions by a staggering 20%. Such reductions would be very welcome, especially in the run up to

the Paris Climate Summit taking place in December. This is a huge missed opportunity because

fossil fuel subsidies are still vast, and they are a real blockade to changing transport. The IMF

estimates global fossil fuel subsidies to reach €4.7 trillion in 2015. The EU is estimated to only have

a small share in this enormous amount, but Europe’s fuel transport sector will still benefit from

approximately €18 billion in subsidies in 2015.

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http://www.theicct.org/publication-type/reports


Environmental Pillar submission56

to Consultation on Investing in our transport future - A strategic

framework for investment in land transport, a policy that appears to have completely forgotten

climate change.

Transport Recommendations:

• Tax carbon at a level where it will encourage the move away from fossil fuels. Sweden with a

CO2 tax of €150 t/CO2 is a good example of a good social protection system, a competitive

industry and decoupling of growth from carbon. 57

•••• Stop subsidising fossil fuel. When unleaded petrol became cheaper than leaded everyone

made the switch. Make electricity the more attractive option.

•••• Improve and incentivise transport options available to the public by encouraging a joined up

transport systems across public and private sectors.

•••• Decarbonise all public transport systems.

• Read the Environmental Pillar submission58

to the transport framework and consider that A

Strategic Framework for Investment in Land Transport must be written in the context of the

climate change challenge and National policy in relation to transition to a low-carbon

economy.

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Consultation-on-Investing-in-our-transport-future-1.pdf 57

http://www.carbonpricingleadership.org/news/2015/5/24/sweden-decoupling-gdp-growth-from-co2-emissions-is-

possible 58


Consultation-on-Investing-in-our-transport-future-1.pdf


9.0 Housing

It is estimated that some one million Houses in Ireland are in need of upgrading to reach the BER

standard A rating. Following the outline below, retrofitting these houses would:

• create employment in the depressed building industry,

• address one of the underlying issues of fuel poverty,

• dramatically reduce greenhouse gas emissions

• increase tax receipts

• boost the wool industry, at present in dire straits, by promoting wool insulation as part of this

package

UK figures estimate an average cost of £25,000 per house for a full retrofit. Assuming a similar

figure for Ireland, we are looking at a total of €25 billion at today’s prices.

The proposal is to establish a system of rolling finance based on interest free loans to house

owners to enable them to carry out the necessary work. The procedure would be as follows.

A householder gets the house assessed, an estimate of costs is agreed and a loan secured to carry

out the work. The Borrower pays back the loan at the rate equivalent to the energy savings

resulting. The net financial effect being that the cost of the retrofit has no impact on the current

expenditure of the house owner. Indeed as energy prices rise there will be a net saving. The

occupier of the house will have a more comfortable home which has a much increased resale

value.

It is suggested here that a target of 40,000 houses a year would be an achievable target at an

overall cost of €1 billion a year. Approximately €120 million would return to the government as

VAT and perhaps another €100 million as income tax. The initial capital for this could be sourced

in the Ethical Funds globally or through the World Bank Green Bonds59

Housing Recommendations:

•••• Massive Investment in retro fitting Home Insulation through “Pay As You Save” scheme.

•••• Continue with and expand the Better Energy Communities scheme, run by the SEAI

Sustainable Energy Authority of Ireland.

•••• The Environmental Pillar proposes that a community energy policy be devised and its

implementation be adequately resourced.

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treasury.worldbank.org/cmd/htm/WorldBankGreenBonds.html


• The Environmental Pillar Policy Statement60

on the Flooding Crisis November 2009 outlines many

planning considerations in climate mitigation.

Contact Details Michael Ewing Coordinator, The Environmental Pillar Knockvicar, Boyle, Co Roscommon Rep of Ireland F52 X821 Tel: +353 71 9667373 Mob: +353 86 8672153 email: [email protected] web: www.environmentalpillar.ie Twitter: @MichaelEwing1 Skype: michaelk.ewing This submission was developed using the Environmental Pillar processes but is not necessarily the policy of each member group in the Pillar. Environmental Pillar members: An Taisce. Bat Conservation Ireland, BirdWatch Ireland.

CELT - Centre for Ecological Living and Training. Coast Watch. Coomhola Salmon Trust. Crann. ECO UNESCO. Feasta. Forest Friends. Friends of the Earth. Global Action Plan Ireland, Gluaiseacht. Good Energies Alliance Ireland, Hedge Laying Association of Ireland. Irish Doctors Environment Association. Irish Natural Forestry Foundation. Irish Peatland Conservation Council. Irish Seal Sanctuary. Irish Seed Saver Association. Irish Whale and Dolphin Group. Irish Wildlife Trust. The Native Woodland Trust. The Organic Centre. Sonairte. Sustainable Ireland Cooperative. VOICE. Zero Waste Alliance Ireland

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http://environmentalpillar.ie/policy-statement-on-the-flooding-crisis-november-2009/

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