Northern Ireland’s 2030 and 2040 Emissions Reduction Targets and First Three Carbon Budgets consultation response

1. Introduction

Climate breakdown is the greatest threat facing civilisation. UN Secretary General, António Guterres, has said we have now reached the era of global boiling. We are rapidly running out of time to take effective action.

The growing climate crisis requires immediate action that is sufficient for the scale of the crisis. The transition must also be just, ensuring communities aren’t left behind, or that we use a disproportionate number of resources. To date, Northern Ireland’s response has been inadequate. Further action is greatly hampered by the derogated methane emissions target of the Climate Change Act, the continuing push for expansion of the gas network, and rising transport emissions.

Northern Ireland’s per capita emissions are higher than the UK average, accounting for 4% of the UK’s total emissions. In addition, Northern Ireland’s emissions are falling significantly lower than the UK average, achieving just 23.2% reduction compared to the UK’s 47.7%. If Northern Ireland is to do its fair share in tackling climate change, there is simply no room in the carbon budget for new fossil fuel infrastructure or exploitation, and we must make a rapid transition to a zero-carbon society as soon as possible.

It is important to get the trajectory of emissions reductions right. That means making rapid and steep cuts early. Ambitious carbon budgets are needed in order to set the framework within which policies and plans can be written to ensure the required emissions reductions trajectory is achieved.

The development and implementation of budgets, climate action plans, and climate policies is greatly hampered by the departmental organisational tie-in with green growth. Continuous growth, green or otherwise, on a finite planet is a physical impossibility. It must necessarily come up against the finitude of the earth’s resources and the capacity of the atmosphere, the oceans, and other sinks, to absorb pollution. We won’t make progress in tackling the multiple crises facing us until we let go of the idea of growth and build a new economic model that reflects physical reality.

2. 2030 and 2040 targets

The 2030 and 2040 interim targets are the minimum required to meet the overall net-zero by 2050 target. However, the interim targets are not ambitious enough to meet the global requirements to tackle climate breakdown. The Northern Ireland Climate Change Act expresses the targets as at least 48% reduction by 2030, and at least 77% reduction by 2040. The inclusion of at least is crucial. It implies more can be down. The science requires more to be done. The interim targets must not be treated as maximum reductions, but as minimum reductions, with the intent to go beyond them.

Figure 6, on page 30 of the consultation document, charts various emissions reductions pathways. The recommended option, the Stretch Ambition pathway, describes what is essentially a straight line from 2020 to a 93% reduction by 2050. The goal of carbon budgets should not be to simply chart out a trajectory to meet the end target, but to maximise greenhouse gas reductions. The planetary climate system doesn’t care if targets are met or not. What matters is the volume of greenhouse gas emissions in the intervening period. The area under the curve is crucial. The carbon budgets, and subsequent Climate Action Plans, should front-load greenhouse gas reductions in order to minimise the total greenhouse gas emissions over the period to 2050.

3. Carbon Budgets

In order to have a good chance of staying below a 2^oC temperature rise, the planet as a whole is limited to around 800 billion tonnes of CO₂ (GtCO₂). If we are to stay below 1.5^oC, the preferred target in the Paris Agreement, we cannot emit more than about 400GtCO₂. With a global population of around 7.8 billion people, this equates to about 51 tonnes per person. Currently, the average emissions per person in Northern Ireland are around 12 tonnes per year. Given this, Northern Ireland will exceed its 1.5^oC carbon budget in under 5 years.

It is worth bearing in mind the scientific paper referenced above was published in 2016, 7 years ago. It is likely, therefore, that Northern Ireland is close to exceeding, or has already exceeded its 1.5^oC carbon budget. It is clear the time for strong action is now. The proposed carbon budgets must be developed in this context. Minimising the total emissions over the period to 2050 should be the primary goal.

4. Agriculture

Agriculture is the biggest single producer of greenhouse gas emissions, and those emissions are continuing to rise. Methane, around 77% of agricultural emissions and about 25% of total greenhouse gas emissions, is a particularly potent greenhouse gas more than 80 times more potent a greenhouse gas than carbon dioxide over a 20-year period. However, it is a relatively short-lived gas, breaking down in around 12 years. Its short-term potency means it is crucial immediate action is taken to reduce it.

The Climate Change Act states, “the duty in subsection (1) [the net zero target] does not require the net Northern Ireland emissions account for methane for the year 2050 to be more than 46% lower than the baseline for methane”. However, the consultation document states, “…the Act’s requirement that reaching Net Zero in Northern Ireland does not reduce methane emissions by more than 46% on 1990 levels by 2050.” These are not the same thing. The consultation document appears to be misinterpreting the Act. There is nothing in the Act that precludes methane emission reductions being greater than 46% by 2050. The requirement is that a 46% reduction by 2050 is reached. This is another example of minimum targets being interpreted as maximums. Given the short-term potency of methane, emissions reductions should be front loaded, not left as an afterthought.

According to the Global Methane Assessment from the Climate and Clean Air Coalition, cutting methane will not only make a significant contribution to tackling the climate emergency, but will also save lives and increase productivity.

Methane is not the only agricultural emission that is problematic. Nitrogen and its oxides are also a problem, not just for climate change but for other types of pollution. A Nitrogen Budget, similar to the Carbon Budget should also be developed. Scotland has set a precedent by including a Nitrogen Budget in its Climate Change Bill, and Northern Ireland should follow suit.

By far the quickest and surest way of reducing emissions from agriculture is to reduce livestock numbers. Agricultural policy seems to be driving an increase in livestock numbers, however. Farming needs to change from an intensive, industrial model to a sustainable one, better suited to the imperative to combat climate breakdown. It should shift towards a diversity of produce, including fruit and vegetables, silvopasture using appropriate tree species at an appropriate planting density, and regenerative and conservation farming. A progressive farming policy would seek to restore wild places, while paying farmers to be custodians of the land. Reforestation of uplands, for example, would stabilise the ground, absorb water thereby reducing flooding incidents, created shelters for grazing animals, and provide an alternative income for farmers. The industrial farming model has turned farmers into exploiters of the land. We think their role as custodians of land should be recognised.

Technical fixes of the type mentioned in the consultation document will help, but it’s likely their impact will be limited. Caution should also be applied to speculative solutions that have not yet been tested or developed, or in some cases, even conceived of. Fantasy and wishful thinking don’t make for good policy. The only long-term, sustainable option is to rethink our agricultural model. Project Drawdown describes many viable alternative models that could be developed in Northern Ireland. We shouldn’t wait for the second carbon budget to begin making the transition. It should begin immediately. Farmers must, therefore, be supported in the transition to net zero.

5. Land use

There is a danger that the urgent need to tackle the climate crisis might have unforeseen negative consequences in other areas if care isn’t taken. For example, the consultation document mentions significant reforestation and bioenergy crop planting for use in anaerobic digestors. Reforestation is essential, not just to tackle the climate crisis, but also to reverse biodiversity decline. More conifer monocultures are not an appropriate response to the crises, however. Tree planting should be restricted to species of local providence planted in appropriate locations. Consideration should also be given to fencing off areas and allowing them to reforest and rewild naturally.

Anaerobic digestion is an appropriate technology for the disposal of organic waste such as some agricultural waste, forestry cuttings, and food waste at a small, local scale. Problems arise, however, when industrial scale plants are developed as a solution to the large volume of waste generated by intensive factory farms. AD used in this way is associated with a range of environmental problems. For example, there is already a serious problem with ammonia and nitrogen from agriculture. 98% of Special Areas of Conservation (SACs) and 83.3% of Special Protection Areas (SPAs) had nitrogen deposition rates exceeding their Critical Load. These are NI’s most important habitats. The ammonia emissions from the storage of the feedstock, the anaerobic digestion process, the storage of the digestate, and the land spreading of the digestate are estimated at 1.4 million kilos of ammonia per year. Far from solving the problem, the proliferation of industrial scale ADs is exacerbating it.

In order to produce enough methane to make the plants economically viable an equal mass of grass or maize silage is required. The scale of AD developments means a large area of farmland is taken out of food production in order to feed the AD plants.

AD plants for certain organic waste products should be part of the solution. They should not, however, be developed as cover to perpetuate an unsustainable agricultural model.

Biomass is also a problematic proposal. There may be limited use for biomass fuels but there also problems associated with it. Opting for purposely grow biomass may take land out of food production, potentially driving up food prices. There is also a risk that if there is a major increase in biomass burners, and possibly biomass powerstations, local production may not keep up with demand. The demand deficit would likely be filled by biomass produced in the US, Canada, and Brazil. Such biomass production is associated with the destruction of old growth forests, and human rights abuses of indigenous people. A just transition must be an equitable transition. Solutions involving human rights abuses should not be considered.

Domestic biomass burners, such as wood pellet burners, have been shown to increase indoor particulate levels, resulting in health problems.

6. Buildings

Buildings are a significant contributor of greenhouse gas emissions. They also offer some quick wins. The focus for buildings should be firstly on energy efficiency, and then on renewable energy. Technologies such as heat-pumps and photovoltaics are likely the best options for domestic, civic, and commercial buildings.

Building regulations should be amended to require the highest levels of energy efficiency for all new builds. A Green New Deal type of programme of public works to improve the energy efficiency of existing homes should be rolled out.

Public buildings are ideal for larger scale renewables projects. The public sector owns a significant amount of roof space and land which could be utilised for renewable energy.

7. Energy

If Northern Ireland is to be serious about playing its part in tackling climate breakdown then the energy sector must be transformed. The two primary components of a zero-carbon energy sector are much improved energy efficiency, including efficient distribution, and a shift away from fossil fuels to renewables.

The most cost-effective emissions reductions can be made through improved energy efficiency. Energy efficiency not only saves money, but also cuts greenhouse gas emissions, and as part of green recovery programme, can create thousands of good quality jobs. Energy efficiency makes environmental and economic sense for households, the public sector, and for business. Generation should ideally be based on distributed generation in combination with renewable capacity in individual buildings.

A grid built on renewable energy technology has to be able to cope with intermittency and a variety of technologies dispersed across Northern Ireland, as well as provide adequate storage capacity to maximise generation efficiency. The grid is currently experiencing some bottlenecks in key areas, with the result that current generating capacity isn’t being efficiently utilised. The grid, therefore, needs to be upgraded to cope with both current and projected future generating capacity.

Energy policy must also learn the lessons of the RHI and the AD scandals. We must be alert to possible negative consequences of any proposals. The RHI and AD schemes were corrupted by people wishing to profiteer off them. As a result, they were counterproductive, both in emissions reductions and in public confidence in emissions reductions schemes.

The public sector is a significant user of energy, and has considerable spending power. A transition to a zero-carbon public sector and use of public land for community owned renewable energy projects would stimulate the market, and provide leadership for the rest of society.

Alternative models of ownership of renewables projects should be explored. Many for profit projects have been problematic and turned communities against renewables. Community owned and co-operative models are more likely to ensure local support and have an easier passage through the planning system.

There should be no extraction of fossil fuels. All indigenous fossil fuels should be left in the ground. Exploiting indigenous fossil fuels is entirely counter to the aim of creating a low-carbon society. The world’s limited and depleting carbon budget should be used to enable the global south to develop. In addition, there should be no new fossil fuel infrastructure. If the premise that we must move towards a low carbon society is accepted, then investing in new fossil fuel infrastructure is both a waste of time and money. We will have to do it sooner or later. Doing it sooner will help to minimise the total emissions to 2050.

The public sector should completely divest from fossil fuels, and invest in renewables and other low- and zero-carbon technologies. This would send a clear signal about in which direction society must move. It’s also economic sense. Fossil fuel investments will become devalued stranded assets.

8. Transport

Transport is the second largest emitter of greenhouse gases in Northern Ireland. Like agriculture, transport emissions having been rising. Transport strategy should be focused first on reducing the number of journeys, and particularly private car journeys. The document proposes a hierarchy of substitute trips, shifting modes, then shifting fuels. We support this proposal. However, there should be much more emphasis put on reforming the planning system so that people don’t have to travel so much. The proposed Transport Plans are described as setting out a transformative vision. Such a transformative vision is welcomed and is needed for the whole of society and our economy.

Electric vehicles will play a role in a zero-carbon future but there should not be an over-reliance on them. There are serious problems associated with the extraction of rare earth minerals and other materials needed for electric cars. The principle of a just transition requires that we do not use a disproportionate number of limited resources or offload environmental destruction onto others. Travel reduction, active travel, and public transport should be the primary focus.

9. Business and industrial processes

Care should be taken that there isn’t an over-reliance on Carbon Capture and Storage. CCS is an untested technology with significant problems, such as finding appropriate storage facilities, and securing those facilities for many centuries to ensure the carbon does not escape. Policy should be focused on measures that reduce emissions in the first place, such as energy efficiency and renewable technologies.

Plans to develop a hydrogen economy need to be considered very carefully. Hydrogen is a much-vaunted technology. While it will have a role to play under certain circumstances, it isn’t the silver bullet its proponents claim it is. It should be limited to uses where there is no other low-carbon alternative. 

The method of production of hydrogen is a crucial factor. Blue hydrogen, produced using fossil fuels, should not be considered as part of Northern Ireland’s energy mix. Blue hydrogen is a significant emitter of greenhouse gas emissions. The Climate Change Committee estimates emissions from blue carbon production using natural gas to be around 285gCO₂/kWh. However, when fugitive emissions are factored in, blue hydrogen produces an additional 15-70gCO₂/kWh, but may be 25 – 40% higher.  To put that into perspective, the carbon intensity of the entire UK grid was less than 200gCO₂/kWh in 2019, making blue hydrogen significantly more carbon intensive than the current grid.  

Hydrogen produced using renewable electricity, green hydrogen, is a better option. However, although there are no additional emissions from green hydrogen, its production is not 100% efficient, so there will be an increase in carbon intensity. It is more efficient to simply use electricity generated by renewables directly for power or heat for most sectors, rather than introduce an additional inefficiency into the mix. 

Hydrogen is an important element in the transition to a low-carbon society. We must not rush to develop it though. Blue hydrogen will increase greenhouse gas emissions, is counterproductive, and must be rejected as an option. Green hydrogen can pay a role where no other low-carbon alternative is viable, such as in industry and road haulage, for example. The use of green hydrogen must be prioritised according to need, and not left to the whims of the market though. Without a strategic focus it is likely to suffer the same fate as RHI, Anaerobic Digestion, and other green technologies that have proven to be problematic. 

Hydrogen may play an important role in the future, and further research and development is appropriate, but it would be short-sighted to draft an energy strategy predicated on the assumption that it will be available and affordable in the near future.

10. Waste

The consultation document states DAERA’s focus is on reducing the amount of waste going to landfill. However, the focus should be on reducing the amount of waste generated. This is a subtle but important distinction. The easiest waste to deal with is the waste not produced in the first place.

Reducing the amount of waste going to landfill is vitally important, but having it as the primary focus may lead to false solutions such as incineration. Incineration doesn’t make waste disappear, but merely replaces it with toxic ash which still needs to be disposed of, usually to specialised landfill capable of taking hazardous waste.

Incineration is described as energy-from-waste. However, it is not an efficient way of producing electricity. In many cases more energy is required to replace the product that has been burnt than is generated by burning it. So, if a full lifecycle analysis is carried out, incineration is a net user of electricity. In addition, for incineration to come close to being an efficient energy generator, waste with the highest calorific value must be burnt. Such waste tends to be the most easily recycled, such as food and garden waste, paper, and plastics, so again incineration would undermine the development of more sustainable options.

11. Fisheries

The pressing need to decarbonise the fishing industry should be used as an opportunity to reform it. The most environmentally damaging fishing types should be phased out and measures taken to reduce the amount of plastic pollution discarded into our seas.

Just transition principles apply equally to the fishing industry. The industry will have to undergo significant transformation. People employed in the industry should be supported to replace or retrofit their boats as appropriate, or retrain to enable them to move into other sectors.

12. CCC Advice

The Climate Change Act (Northern Ireland) 2022 includes a target for net-zero emissions by 2050. That target is a legal obligation. It is strange, therefore, that the document is seeking views on a 93% reduction target.

The 93% reduction target is political, not scientific. It is based on technological capacity, economics, and an assessment of how quickly people and business can change and adopt new technology and new ways of working. This is confirmed by the Climate Change Committee. In its Sixth Carbon Budget the CCC said, “there is no purely technical reason why net zero is not possible in Northern Ireland”. If not technical, the reasons must be political, economic, or structural.

In reference to the shift from an 80% reduction target to net-zero, the CCC’s Advisory Group on Costs and Benefits of net-zero stated, “One advantage is that it removes uncertainty and the temptation of sectors to lobby for a larger share of the remaining 20% of emissions. The clarity of a ‘net zero’ goal, coupled with good policy design, could help stimulate innovation across all sectors, and cut the cost of capital, thereby bringing down the overall cost of mitigation.” It’s unlikely the market mechanisms the Advisory Group is basing its conclusion on are different for Northern Ireland. The actions needed for Northern Ireland to take its fair share of the actions needed to tackle climate breakdown are within the remit of the Assembly.

13. Fair share

Northern Ireland’s per capita emissions were about 10.3tCO₂e/year in 2019. To put that into perspective, the UK average was 6.8tCO₂e/year, the per capita emission in China were 7.1tCO₂e/year, 1.23tCO₂e/year from Bangladesh, and the people of Kiribati produce 0.95tCO₂e/year.

A 1 metre rise in sea levels is projected to flood or negatively affect about 1/3 of Bangladesh, impacting around 35million people. Kiribati is already being impacted by climate change, with its freshwater routinely being contaminated by sea water. Drastic plans are being drawn up to raise the entire island nation or evacuate the whole population. Kiribati is on track to becoming the first nation completely destroyed by climate change. Bangladesh, Kiribati, and many other nations and communities around the globe are contributing little to the problem but are facing the brunt of the impacts.

Not only is Northern Ireland producing above its global fair share of emissions, it is also producing more than its UK fair share. UK average emissions fell by 47.7% since 1990. Northern Ireland’s emissions fell by just 23.2% over the same period. Northern Ireland is not pulling its weight in the fight to tackle climate breakdown.

Accepting a carbon budgets for a 93% reduction target is tantamount to claiming the people of Northern Ireland deserve more of the earth’s atmosphere than people in England, Scotland, Wales, China, Bangladesh, or Kiribati. That isn’t a position that can be justified scientifically, politically, or ethically. Northern Ireland has both a current and an historic responsibility to act immediately, with ambition, leadership, and compassion.

14. The consultation

The consultation is deeply flawed. The questions are prescriptive and leading. They often contain false dichotomies and flawed assumptions. It is for these reasons that Friends of the Earth has opted not to answer the questions as written, and instead state what we believe to be what is required in order to effectively tackle climate breakdown in as timely, science based, and fair way as possible.

15. Conclusion

Climate change is the most important issue facing this, or any other, generation. The recent IPCC report is clearer and more confident than ever before about the downsides to global warming. However, scientists are hopeful that if we can cut global emissions in half by 2030 and reach net zero by the middle of this century, we can halt and possibly reverse the rise in temperatures.

It is imperative that prosperous nations like Northern Ireland show strong leadership in this time of crisis. The arguments in favour of ambitious carbon budgets equal to the task required are supported by the most up-to-date science, economics, and ethics. Strong climate action is good for people, good for the economy, and good for the planet. It is essential if Northern Ireland is to take advantage of the inevitable move to a low-carbon global economy. The proposed carbon budgets are simply not strong enough and cement Northern Ireland’s status as a climate laggard.