Public Consultation on Carbon Budgets

Fri, Feb 4, 2022

Read in 8 minutes

The public consultation on Carbon Budgets is coming to a close (8th Feb). Find out below how to make a submission and see some of the observations I will be making (which you are free to borrow/amend for your own submission).

Public Consultation on Carbon Budgets

Below are the points I’ll include in my submission. Feel free to copy/amend for your own submission. If there’s something you think we’ve missed please let me know.

Globally the term “carbon budget” is most often understood to refer to the total net amount of carbon dioxide (CO2) that can still be emitted by human activities while limiting global warming to a specified level. The proposed carbon budgets will require transformational changes for society and the economy which are necessary; failing to act on climate change would have grave consequences. The proposed carbon budgets must be consistent with an appropriate contribution by the State to global efforts to limit climate change to well below 2oC and pursuing efforts to limit the temperature increase to 1.5oC as articulated in the UNFCCC and the Paris Agreement.

The first two carbon budgets, proposed by the CCAC, bringing us up to 2030, must account for a 51% reduction in emissions relative to 2018 levels, while the provisional third budget, bringing us up to 2035, must be consistent with establishing a credible pathway to net-zero emissions by 2050

Although Ireland faces challenges, like many other countries, in achieving carbon reduction emissions it is imperative that the targets we set in our national carbon budget reflect the science that underpins globally agreed climate action. The public consultation document states ‘. The carbon budgets will be consistent with furthering the achievement of the national climate objective and include all greenhouse gases. The first carbon budget programme will comprise carbon budgets for the following periods: 2021-2025; 2026-2030 and 2031-2035.’

To limit global temperature rise to the necessary 1.5 degrees by the end of this century, we must reduce emissions by 45 per cent from 2010 levels by 2030, and we must achieve climate neutrality by 2050. The United Nations Environment Programme annually publishes an “emissions gap” report, which considers the gap between how much countries are planning to cut emissions and what is required to keep global heating to 1.5C, the goal of the Paris Agreement. This report has stated that we need to “cut global emissions by 7.6 percent every year for the next decade to meet 1.5°C Paris target”. Therefore it is imperative that we work from the base of 7% (or indeed 7.6%) in developing our nationally agreed carbon budgets.

Given that rich countries have polluted more than developing countries and have greater capacity to make carbon savings it is incumbent on wealthier countries like Ireland that we not only meet our base targets but operate in a manner that may exceed those targets. A number of academics in the state have outlined that given the level of emissions Ireland produces per capita even the 7.6% emissions reduction does not signify doing our ‘fair share’ and indeed a more careful nuanced accounting might a produced a target above 10%.

For the carbon budgets to operate successfully it is imperative that both the sectoral allocation process and the subsequent accounting is analytically robust, transparent, and involve wide stakeholder consultation. The carbon emissions accounting structure must be developed specifically and explicitly to guard against the double or forward counting of emissions reductions. Many contributors to the various debates of the Joint Committee on Climate Action have eloquently outlined this point.

“It must deliver the reductions in emissions without recourse to offsetting or other accountancy ruses.

In relation to its CO2 emissions from energy, the reductions must be delivered through policies driving conservation (consuming less energy services), efficiency (consuming energy more efficiently) and the rapid and complete switch from fossil fuels to low/zero carbon alternatives. It must not rely on speculative negative emission technologies (NETs) or wider ‘carbon dioxide removal (CDR)’ options. Similarly, it must not assume the large-scale uptake of carbon capture and storage (CCS) applied to fossil-fuelled power stations"(1)

Similarly for the sake of public confidence and fairness emission reduction targets must be economy wide and and sectorally balanced.

Ultimately the only important measure of climate and air pollution action is absolute, instead of relative. No sector can be removed from or given a different weighting to others. Dr. Paul Deane of UCC has estimated that if agriculture only achieved 10% emission reductions, the buildings, energy and transport sectors would have to do more than 70%.

Agricultural emissions of methane, nitrous oxide and ammonia have been increasing steadily since 2011 due to dairy expansion and greatly increased nitrogen inputs, with only a minimal reduction in beef cattle numbers. Requiring herd reductions from beef farmers will not by itself address the water and biodiversity impacts from the dairy sector that we highlighted in our report, jointly published with the Environmental Pillar and SWAN, and may even lead to rebound effects as more land becomes available for silage production for dairy cows. Without substantial and sustained reductions in agricultural methane over the next decade it will not be possible to meet current national and EU climate targets.”(2)

National carbon budgets are necessarily calculated on the basis of an effort-sharing equality principle. All sectors, all communities, all workers. However the reality is that some communities will experience more significant change than others and every aspect of our response to climate change must be through the lens of a Just Transition.

The proposed carbon budgets will have an impact on the economy but failing to act on climate change would have greater consequences. The negative impacts of both mitigation and adaptation can be navigated by appropriate policies and supportive infrastructures to communities and persons most effective. Without these supports as a subset of carbon budgets it is unlikely that community action will be of a suitable scale to address the crisis.

A state-led approach to a formal Just Transition policy that operates within the parameters of a carbon budget must be predicated upon putting the productive assets of climate action, and its supply chains, into the control of communities so that they can lead their own development. This would be truly transformative.

It can be done by adopting a community wealth building approach to climate action. It is the structure of carbon accounting that will underpin cooperative and community ownership of the new climate driven innovation and economies. The ownership of infrastructure and access to investment stream would support communities to harness technologies such as windmills and solar farms so that they can use the returns to develop community centres and sports clubs.

Although a largely new proposition the Just Transition model represents an unprecedented opportunity for some communities- “This lack of practical templates is an opportunity for Ireland to lead on an internationally regarded example of just transition in the Midlands. As other countries begin their transitions, Ireland can serve as an international example of a proactive, inclusive and place-based just transition to an economy that operates within environmental and social limits.”(3)

The climate crisis requires state-led green industrial and innovation policy supported by unprecedented capital investment. Given the scale of the climate crisis, a state-led investment approach should now be prioritised led by Just Transition principles.

While Just Transition methodologies may be harnessed to address the impacts to particular communities of climate action and economic change the more granular effects to specific households are often less clear. Lower income households in Ireland, which typically are lower emitters of CO2, are more likely to find the impacts of policy change will further constrain their purchasing power or increase their cost of living. Policy makers, rightly, are concerned that new measures may push households into fuel poverty or worse. This scenario has largely led to inertia on the issue and has not in fact protected families from the worst consequences of climate change and increasing energy costs.

Ten percent of the world’s population are responsible for an approximate half of all greenhouse gas emissions, while those in the lower half of the household income bracket contribute just 12% of all emissions. This is not simply indicative of wealthier countries versus the less wealthy but a more fundamental divide- there are high emitters in poorer countries and low emitting households in some of the world’s wealthiest nations.

The investment in low carbon technology in the coming years must be mindful of this reality, while balancing this with historic inequalities that may sometimes challenge the ‘polluter pays’ principle. Similarly a global effort on climate action will require a fully transparent carbon budgeting process and takes into account the effort sharing ability of other nations (including energy demands, access to fuel resources, vulnerability to climate change and human rights based, socio-economic metrics.)

How do I make a submission

The closing date for submissions is 5.30pm on 8 February 2022.

Submissions should be sent by email to or by post to:

Climate Division – Carbon Budgets,

Department of the Environment, Climate and Communications,

29-31 Adelaide Road,


D02 X285