2021 Climate Action Plan
18th May 2021Minister Eamon RyanDepartment of the Environment, Climate and CommunicationsClimateConversation@decc.gov.ieRe. Climate Conversation- Climate Action Plan 2021 Dear Mr. Ryan,I am writing to you in response of your departments call for submission regarding the upcoming 2021 Climate Action Plan and in my capacity as Dublin’s MEP and a member of the European Parliament’s ITRE and TRAN committee. I would firstly like to thank you to have given me and the wider Irish public the opportunity to consult you on this very important topic, and look forward to the results of the Climate Conversation initiative.It was recently found that fifty-nine percent of Irish citizens wish to increase our climate targets. This figure rises to eighty-one percent with regards stricter targets for the transport and building sectors[1]. You, the Minister for Environment, Climate and Communications, possess the significant potential and ability to meet the wishes of the majority of our citizens in the development of not only an environmentally sustainable future but also a socially sustainable future at this critical juncture in our planets history.In order to divert from the global course of a 2°C global average temperature change, it is necessary to reach a net-zero economy by 2040. As you recognise, this is a more ambitious target that the one promulgated by the European Commission. Consequently, I urge more ambitious targets and measures for the 2021 Climate Action Plan beginning with the full phase-out of fossil fuels as soon as possible. It is necessary to phase-out fossil gas as soon as possible in the production of electricity, and progressively in other sectors (transport, industry) as alternatives emerge. This requires rigorous application of the energy efficiency first principle (EE1st) in all sectors in addition to an ambitious energy efficiency and energy savings policy. I recognise that renewable electricity is unlikely to serve all energy needs. However, all assessments of hydrogen for energy system integration must exclude consideration of hydrogen produced from fossil energy. Only truly green hydrogen produced from renewable energy should be considered and enabled. Renewable hydrogen produced from 100% renewable electricity sources can play a strategic role in decarbonising those sectors of our economy that are hard-to-electrify. However, the goal must remain to remain to electrify as much as possible, as using the electricity directly to power cars and warm houses is far more efficient than fuels produced from hydrogen[2].It must be acknowledged that mobility is an essential feature of our modern life. Therefore, it is necessary to make transport environmentally and socially sustainable to ensure its greatest benefit for people and planet. Private car ownership dominates mobility in Ireland. Private car mobility is frequently the de facto choice for many in rural (and urban Ireland) but has significant social and environmental downsides, due to the high up-front and maintenance costs and externalities that are not fully accounted for. Internal-combustion engine car sales should be ended in Ireland by 2035 (if not sooner) to reach decarbonisation by 2050[3]. I urge the 2021 Climate Action Plan to include binding and substantive measures to end the sale of internal combustion engines by the earliest possible date to ensure that we achieve this target. In order to allay mobility requirements brought on by this, substantive investment in public transport and shared mobility in both urban and low-density areas is necessary. The modernisation and maintenance of the existing infrastructure and the development of multimodal transport should be an essential objective. However, when modernising, and allocating funds for modernisation, it is important that “modernisation” centres sustainability - for the environment and society - and divests from the heavily subsidised road network. Investing further in the road network will only result in increased demand for these roads and private car mobility generally. To this end, it is necessary to develop the railway network - including building and or reopening of lines - subsidised ferry links for international travel, and an end to the centrality of the car in towns and cities. This requires cheaper public transport fares (public transport is a public good, and should not be viewed only through the profitability lens), improved cycling and walking infrastructure, annual reductions in the total number of car parking spaces in urban areas. In tandem with provision of better public transport, domestic flights should be banned when a sustainable alternative exists (e.g. Dublin to Cork by train), and rail connections at ports should be improved to increase rail freight within Ireland. Within our urban areas, it is apt to introduce several car-free Sundays per year, congestion charge based on tonnage (proceeds of which can be used to invest in public transport).I recognise and appreciate the department’s attention to renovation of buildings in the built environment. However, I believe it is appropriate and necessary for the 2021 Climate Action Plan to pre-empt the revision of the EU Energy Efficiency Directive (EED) and Energy Efficiency of Buildings Directive (EEBD), which will be revised in line with the European Green Deal[4]. These policy initiatives need to deep renovate the worst energy performing buildings but can also provide wider economic and social benefits. Accordingly, I wish to bring your attention to integrated renovation programmes (IRPs). This is a holistic neighbourhood approach, putting energy efficiency first, while focusing on the broader local, regional and neighbourhood ecosystem, thus achieving important co-benefits. IRPs consist of three main pillars:
The implementation of this three-pillar approach ensures that IRPs, and renovations generally, are devised and implemented in a way that focuses on the wider benefits that can be provided, such as energy efficiency, climate change resilience, industrial competitiveness, sustainability, social inclusion and accessibility. Furthermore, by facilitating the community, local and regional scale local value chains are integrated. In order to achieve this, local authorities need to be empowered with a view to rolling out IRPs at neighbourhood and community level and to ensure that programmes centre citizens. This will ensure the development of a virtuous feedback loop for future programmes, ensuring best practice examples and lessons for future policy design. Additionally, it is necessary to set aside funds to tackle energy poverty, accessibility and technical and infrastructure barriers for vulnerable and low-income households within this framework. Urgent action on this is necessary. Implementing the aforementioned model can allow building renovations to drive the economic recovery from the COVID crisis, creating local and sustainable jobs, mainly in SMEs. This will deliver a social and sustainable recovery, decoupling emissions from growth as was advised in the recent OECD report on Ireland’s environmental performance[5], while assisting Ireland in achieving sustainability targets.My thanks for the good work which you and your department have carried out to date. I look forward to the publication of the much awaited 2021 Climate Action Plan.Warmest regards,Ciarán Cuffe Ciarán CuffeGreen MEP for Dublin [1] Transport & Environment, YouGov (2021) Over two-thirds of EU citizens want their country’s 2030 climate target raised[2] Ueckerdt, F., Bauer, C., Dirnaichner, A. et al. (2021) Potential and risks of hydrogen-based e-fuels in climate change mitigation. Nat. Clim. Chang. 11, 384–393[3] IEA (2021), Net Zero by 2050, IEA, Paris https://www.iea.org/reports/net-zero-by-2050[4] European Parliament resolution of 15 January 2020 on the European Green Deal, paragraph 22, Texts adopted, P9_TA(2020)0005.[5] OECD (2021), OECD Environmental Performance Reviews: Ireland 2021, OECD Environmental Performance Reviews, OECD Publishing, ParisYou can view the submission here.
