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Ireland’s domestic climate policy needs updating to include ten million tonnes of untargeted emissions

posted Apr 16, 2018, 2:03 PM by Paul Price   [ updated Apr 17, 2018, 12:15 AM ]

The Environmental Protection Agency, the EPA, provides Ireland’s most recent complete emission inventory data, up to 2015, published 2017 [pdf]. Comparing inventory emissions with Ireland’s core climate policy it becomes clear that about 10 million tonnes CO2e of Ireland’s emissions (on a GWP-100 equivalence basis) are not currently targeted by national policy, even though these emissions are accounted in EU targets – and do, of course, physically affect Earth’s climate system by adding to global warming. These ‘missing emissions’ are primarily from manufacturing, industry, waste and also ‘F-gases’ (used in refrigeration and air conditioning). In this blogpost, we discuss this issue and some possible implications for climate policy and policy analysis.


Ireland’s current climate action policy, most fully stated in the 2017 National Mitigation Plan, continues to be based on a policy statement made in 2014 called the National Policy Position (NPP). This states that:

“The low-carbon roadmapping process will be guided by a long-term vision of low-carbon transition based on –

• an aggregate reduction in carbon dioxide (CO2) emissions of at least 80% (compared to 1990 levels) by 2050 across the electricity generation, built environment and transport sectors; and

• in parallel, an approach to carbon neutrality in the agriculture and land-use sector, including forestry, which does not compromise capacity for sustainable food production.”


Separately from, and pre-dating, this national policy, Irish emissions are also subject to binding EU emission reduction policies, where emissions are divided between: the EU’s Emission Trading Scheme, the ETS (from large industrial sources, such as power stations, industrial heat use and cement production); and non-ETS emissions, which are limited according to the Effort Sharing Decision whereby each nation is assigned an emissions pathway (allocated by negotiation according to different assessed national mitigation potential).  For the linear, national non-ETS emission pathways each Member State is legally bound to stay within their corresponding allocated total of non-ETS emissions for periods up to 2020, and soon, under the forthcoming EU Climate Action Regulation, to 2030.


However, rather than reflecting this ETS vs. non-ETS distinction, the NPP does not mention the separation at all. Indeed, it mixes them together – the electricity generation facilities are covered by the ETS, whereas the built environment, transport, and agriculture and land-use sectors are all within the non-ETS sector. Built Environment includes mainly heating-associated emissions in the Public and Commercial Services, and Residential sectors.


Logically, as the NPP takes this collective approach to territorial greenhouse gas emissions, ignoring the ETS/non-ETS distinction, we can ask: Are all GHGs therefore included in the key NPP statement quoted above?  Obviously they are not, some major sectors are omitted from mention altogether: there is no targeting of reductions in Manufacturing Combustion, Industrial Processes, F-gases, Waste sectors, or in Energy Industries other than electricity, including petroleum refining, solid fuel manufacture and fugitive emissions. These ‘missing emissions’ amount to a considerable 10.3 MtCO2e or 17% of 2016 total Irish CO2e emissions. See the Excel file here which includes lines below the main tables adding up these missing emissions, for example in the Provisional Summary 1990-2016 sheet detailing total national emissions.  In terms of EU targets, the missing emissions add up to 5.8 MtCO2e or 33% of Ireland's ETS emissions, and 3.6  MtCO2e or 8% of non-ETS emissions.


Even though these territorial emissions are ultimately covered by the EU targets it is striking that there is no mention at all of these key sectors in the NPP.  These omissions are surprising as the NPP is specifically framed in the context of the aligning action with the UNFCCC objectives (now concretely stated in the Paris Agreement) and the associated European Union objective of reducing greenhouse gas emissions by 80-95% by 2050 compared to 1990.  The latter EU 2050 Roadmap assumes EU-wide average reductions of ~85% in Industry and ~74% in non-CO2 (especially Waste and F-Gases) emissions by 2050, yet these sectors are not given a target or included at all in the NPP. It is very difficult to see how deep, economy-wide and sectoral emissions reductions can be achieved if significant sectors are excluded from the explicitly stated targets in Ireland’s climate action policies.



This omission of major sectors from the NPP and the lack of clarity in aligning the policy position with the EU targets undoubtedly has the potential to increase confusion in Ireland’s carbon governance capable of achieving a low carbon transition, especially relative to meeting the separate ETS and non-ETS targets. Sectors outside the NPP definitions could possibly even be incentivised to grow – contrary to the need for decarbonisation across all sectors – simply because their emissions are not readily apparent to policy analysis that is primarily based on the NPP statement that fails to target them.


It should also be of serious concern if some sectors of emissions are not fully included in policy analyses and projections, given that policies will nonetheless need to achieve the EU targets that do include these emissions. Several policy analyses by agencies and researchers released since the NPP are notable for charting the NPP's EGBET emissions yet failing to chart pathways for all CO2 and non-CO2 emissions, thereby overlooking emissions from the omitted sectors. Even if current national policy does not target them, objective policy analysis and projections by agencies, researchers and NGOs needs to assess the trajectory of all of Ireland’s greenhouse emissions relative to international climate commitments.


To avoid the evident risk of overlooking or downplaying the need for climate action by the unnamed sectors, an obvious climate policy recommendation would be to redraft the core NPP statement for the NMP as soon as possible to target all territorial emissions and sectors. (Ideally, the NPP would also state a cumulative CO2 quota in aligned with the Paris Agreement, replacing the currently stated 2050 target, which could result in high total emissions depending on the pathway taken.) As research makes very clear, in the context of the Paris Agreement and the EU objectives, all sectors will need to target substantial and sustained emission reductions.


Updating the National Mitigation Plan to include the missing emissions noted here, by targeting all sectors explicitly, would increase the coherence, effectiveness and ambition of Ireland’s climate action.