There are far-reaching consequences of Ireland not meeting 2030 climate targets that “will have significant implications for the cost of energy to consumers and businesses ... and therefore Ireland’s competitiveness in coming years”, Government officials have warned.
In a briefing paper to government formation talks in January, released under the Freedom of Information Act, the Department of Environment, Climate and Communications said Ireland “is significantly off-target in terms of meeting both its national and EU targets”.
This, it added, will force the Government to buy credits from other complying EU member states, estimated by the Irish Fiscal Advisory Council to cost up to €20 billion. Further comments on the likely cost of compliance were redacted.
It said “based on the national energy and climate plans submitted to date by EU Member States, there may be insufficient surplus emissions units available for Member States to purchase compliance with their respective 2030 targets”.
“Not complying with Irish [climate] law carries significant legal, administrative and political risks”, but missing EU targets “is far more consequential in terms of the financial cost of purchasing compliance”, the briefing paper said.
Ireland’s compliance problem is arising, it added, because “attempts to identify policies and measures to close the gap to national and EU emissions targets has proved challenging, particularly given that agricultural emissions constitute a disproportionate percentage (37 per cent) of Ireland’s GHG [greenhouse gas] emissions relative to the EU as a whole (10 per cent).
“[This] has led to an uneven allocation of effort in terms of reducing emissions, between the agriculture, forestry and other land use sector on the one hand and the broad energy sector on the other.”
The officials added: “This will have significant implications for the cost of energy to consumers and businesses in Ireland and therefore Ireland’s competitiveness ... exacerbated by the misalignment of national and EU systems – a very costly, and likely unachievable, national sectoral emissions ceiling has been placed on the electricity sector to decarbonise by 75 per cent by 2030.”
Decarbonisation costs arising beyond what this sector must achieve under the EU emissions trading system “will be borne by electricity customers, affecting competitiveness and cost of living”, it said.
In the document, the department highlighted a series of “domestic legal risks”.
This includes where the Government may be sued for failing to adhere to its climate action plan – where “it does not provide what the [Climate] Act demands of it, eg a clear roadmap of actions that will achieve the legally required emissions reductions”.
Legal action may arise where “sectoral emissions ceilings” are not comprehensive. This is compounded by an ongoing problem of “unallocated emissions”, which should include necessary cuts in emissions associated with land use, land use change and the forestry sector.
Challenges may be on foot of “a legal requirement of reopen sectoral ceilings in 2025” to allocate additional emission savings, it added, and there is a need to “distribute a likely ‘overspend’ of emissions in the 2021-2025 carbon budget” adopted by the Oireachtas.
This meant excess emissions must be addressed in the following 2026-2030 carbon budget. This carry-over makes it more challenging to meet targets.
The department noted the Climate Change Advisory Council had found the current programme of carbon budgets “does not deliver a 51 per cent emissions reduction by 2030”.
Officials said “development planning decisions and wider Government policy decisions may also be challenged under the Climate Act”.
They identified the need for urgent action on climate adaptation due to increasingly frequent natural disasters.
“Ireland’s climate is also changing in terms of increases in average temperature, changes in rainfall patterns, and weather extremes. These are having a significant impact on our coastlines, including sea-level rise, and on land use and natural resources,” it added.
Making Ireland more resilient should include “particular emphasis on developing and implementing a coastal management plan to build resilience in coastal areas and communities against climate impacts”.
