EPA GHG projections — is agriculture better equipped than other sectors to deliver on climate?
I heard something at a dairy conference I attended last month, which got me thinking.
A speaker stated that, while government policies exist for all sectors to reduce emissions to meet their Climate Action Bill carbon ceilings, none of the sectors are likely, using the existing planned or even additional measures, to reach their obligations. Yet, of all the sectors subject to carbon ceilings, agriculture has the set of plans and measures which will get it closest to its obligations when compared with other sectors.
He was referencing the report issued by the Environment Protection Agency (EPA) in early June, titled “Ireland’s Greenhouse Gas Emissions Projections”. The EPA report sets out to measure, for each sector given an emission ceiling under the Climate Action Act 2021, the extent to which existing planned measures will get them to the target. It then goes on to assess what further progress could be made with additional measures, and how that sits relative to the overall national budgets and the ceilings for each sector.
So, I thought I’d take a closer look at the EPA report. My analysis below is superficial and only focuses on a couple of sectors. I would encourage everyone, whether or not they have an interest in farming, to make it their business to read the EPA report.
What the report says
Generally, the news is not good. EPA tells us that, even allowing for additional measures (additional to those in law in 2021) we will undershoot dramatically our new 2030 EU Effort Sharing Regulation (ESR) target to reduce national GHG emissions by 42% relative to 2005 emissions. Using existing measures, we would reduce by only 11%, while even with additional measures not yet implemented in law, this would only come down by 29%. It should be noted that, later this year, the EU is to complete the above 2030 target with binding, annual reductions to the end of the period. Those will however allow member states to use Emission Trading System (ETS) allowances and credits from actions under the Land Use, Land Use Change and Forestry (LULUCF) sector. You can find out more about these new targets and flexibilities here.
The two projection scenarios used by the EPA in calculating their projections are explained as follows. The scenario With Existing Measures (WEM) includes in its calculations policies, laws and measures that were put in place by the end of 2021, including where relevant the legally binding commitments they relate to beyond that date (e.g. carbon tax increases to 2030). The scenario With Additional Measures (WAM) equals WEM plus the measures that feature in government plans, but are not yet implemented – the EPA gives the example of the target number of electric vehicles which is to reach 945,000 by 2030, but which does not as yet have a delivery action plan to match.
Most sectors face significant gaps between reduction targets and projected emissions. I was particularly curious to see how some of the sectors compared.
If you do a bit of number crunching based on the data in the table below, you find that the electricity generation sector, even allowing for additional measures, will fall just under 13% short of its mandated 2030 target. Transport will be short 9%, industry 23.6%, The ‘other’ category (F-gases, waste and petroleum refining) will fall short 27.3%. The residential and commercial/public buildings sectors are expected to exceed their targets, while agriculture is predicted to fall short by “only” 6.2%. So, agriculture could experience a smaller shortfall than the other sectors that will fall short, which is a relative positive.
What does that tell us about agriculture?
First of all, the EPA projections make it clear that achieving the maximum outcome requires more measures than are currently legislated for in all sectors. It also predicts that with the exception of the building sector, even these additional measures are unlikely to suffice to reach targets, including for agriculture.
It is worth noting, however, that the additional measures for agriculture are known to all farmers, and many of them are already being adopted by large numbers of commercial farmers.
They include measures outlined in the Climate Action Plan 2023, the Teagasc GHG and NH3 Marginal Abatement Cost Curves (MACC) and AgClimatise. I also note that Teagasc are to bring out a new MACC on 12th July, which will offer farmers “pathways to meet the 2030 targets” (source, Gary Lanigan on Twitter) – for obvious reasons, this is not (yet) included in EPA projections.
Not only is there an actual plan in place which consists of practical pathways farmers can readily engage with, there is also a pre-existing infrastructure allowing for greater engagement with the public (farmers) whose behaviour, investments and actions need to change. We have historically close engagement of EU and Government agricultural policy decision makers with farmers, mainly through CAP and other long-established EU agri-environmental laws. We also have the long-standing technical support infrastructure of Teagasc, dairy co-operatives, private consultants and other stakeholders.
The Nitrates regulations restrict all farmers’ fertiliser applications. The BISS basic EU payment scheme under CAP requires all farmers to maintain their land in good agricultural and ecological condition, and now include participation in eco-schemes. There are also a number of Pillar II agro-environmental programmes, including the organic scheme and the new ACRES scheme – the latter involving 46,000 farmers. In addition, farmers have also long engaged with the promotion by Teagasc of their MACC measures through discussion groups and the SignPost network of real-life demo farms, the ASSAP water quality scheme and more.
Do these types of regulations, connections and support networks exist in other sectors?
What about residential building and transport?
The EPA’S projections for the residential building and commercial building sectors suggests that both will deliver a greater GHG cut than they are obliged to deliver by 2030.
Existing measures taken into account by the EPA include the prohibition of oil and gas boilers in new dwellings which will come in 2022 and 2025 respectively. This will only impact significantly after those dates, and assuming that large numbers of dwellings are built rapidly, at a time of major labour shortages.
The additional measures also include the installation of 680,000 heat pumps in the next seven years, 400,000 in existing homes. Air to water heatpump systems cost between €8,000 and €14,500, before grants. The EPA calculation also includes a home upgrading and retrofit to BER standard B2 of half a million homes by 2030. Because of lack of appropriately skilled trades people, the system for those who can afford the hefty investment required even with the maximum grant of €25,000 is bogged down in bottlenecks and waiting lists. The cost of deep retrofitting to householders was estimated in 2022 at €60,000 to €70,000 for a 3-bedroom home. We know materials and labour costs have increased since. The SEAI website indicates waiting times for retrofitting works is between 18 and 24 months. There is an action plan for apprenticeships and the number of programmes across all professional sectors have doubled from 27 to 60 between 2016 and 2020. Over 8000 construction apprenticeships were registered in 2022, but that was slightly down on 2021. The Government’s target is for 10,000 registered construction apprenticeship per year by 2025 to deliver on its housing programme.
For the transport sector, the EPA includes as an additional measure the planned near one million increase in EV numbers on the road, of which 845,000 private cars by 2030. While there are incentive measures by way of grants, zero VRT and lower cost fuel and maintenance, there is no proactive restriction on the operation of petrol or diesel cars. Many car manufacturers have ceased producing diesel versions of their ranges, and more and more bring in EVs. But those remain expensive to purchase, even after (now reduced) grants. The second-hand market remains underdeveloped, with concerns around the life span of batteries. While technology will improve in these areas, and prices will fall, 2030 is only around the corner. Carbon taxes will make diesel and petrol more expensive, but no motorist will likely be forced to take their combustion engine cars off the road.
A more promising aspect might be the increase in public and active transport, and these too are factored into the additional measures by EPA. However, here too, the development of public transport infrastructure seems bogged down in politics and slow planning processes. Minister for Transport Eamonn Ryan himself recognised this, stating last March that delays with An Bord Pleanála decisions are the “greatest constraints facing the country” when it comes to reducing emissions in the transport sector. Hence, important plans such as BusConnects, or Metro North/Metro Link are painfully slow to roll out.
The EPA report makes it very clear that its projections in the WAM scenario require delivery of all the above targets, and those in other sectors, too. But how likely is it that all the bottlenecks will be overcome in time for optimum 2030 delivery, never mind actually reaching targets?
Agriculture well placed, but still has a lot to do
I think the EPA projections are a valuable effort to inform action in all sectors. I know the EPA have poor press with farmers at the moment. Here, they are utilising the best established estimates, models and projections from SEAI, Teagasc, etc. In so doing, they are making it clear that even assuming the delivery of all existing and additional measures in the various sectoral government plans and policies on climate action, a major emission gap remains relative to our legally binding targets.
It is a real wake-up call reminding us we still have an enormous amount of work to do, in every sector.
Agriculture, as I see it, has a huge advantage in that it has a well-developed plan which the people who need to activate it (the farmers) are already engaged with through long-established frameworks. Though they could use greater financial supports for some of the costlier actions, they have a relatively strong level of technical support to deliver necessary action on GHG emissions reduction.
One of the more disturbing aspects of the report from an agricultural perspective, is the much greater projected share of GHG emissions it could represent at the end of the period. This is because other sectors are expected to decarbonise more rapidly by 2030.
This frankly remains to be seen, but objectively, it does not matter all that much. Agriculture’s large share of national emissions is out of kilter with other European countries’ because Ireland’s industrial structure is also out of kilter: we do not have heavy polluting industries in Ireland.
However, this means the focus on agriculture as the largest emitter in Ireland is not about to disappear, and it will be even more vital to strengthen the sector’s credentials in climate action, to show convincing results in the next few years.
© Catherine Lascurettes, Cúl Dara Consultancy
