The Government’s plan to reduce greenhouse gas emissions (GHGs) from the agricultural sector is described as “not credible” in senior-level departmental documents seen by AgriLand.

Last April – just two months before the Government’s official Climate Action Plan was published – Robert Watt, the secretary general at the Department of Public Expenditure and Reform wrote to Mark Griffin, the secretary general at the Department of Communications, Climate Action and the Environment, to cast doubt over the route of travel on tackling agricultural emissions.

Although the final version of the policy set out how to reduce agricultural emissions without cutting herd numbers, in an email – dated April 16 – Watt stressed that the economic argument for reducing the national herd size “should not be ignored”.

Watt wrote:

The agricultural sector represents 46% of Ireland’s national (non Emission Trading Scheme) greenhouse gas emissions. The sector is, by quite some distance, the single largest component of our emissions.

In that regard, I am surprised that the McKinsey analysis [explained below] did not consider the potential for any greenhouse gas abatement options in this sector.

This is not credible.

I understand that McKinsey incorporated the recent Teagasc work into their model; but this work has some critical limitations and was not complied on the same economy-wide basis as the McKinsey work.

It will be difficult to build public support for the climate transition and deliver de-carbonation with just transition without considering agricultural emissions in more depth.

Analysis suggests that a 5% reduction in the national herd would deliver more greenhouse gas emissions savings over the decade than the delivery of the entire energy efficiency component of the draft climate plan.

Since the investment costs associated with 500,000 renovations is likely to be €15 billion, I cannot but conceive that it would be more cost effective to implement a programme which would reduce herd numbers by the negligible amount – while increasing farm incomes.

In some sectors farm incomes are so low and the sector is so dependent on UK exports that a shift to virtually any other form of agricultural activity would likely increase farm incomes and result in better climate outcomes for the state.

There may be significant downsides to these options but to make informed climate choices the Government needs to have information available on the full suite of policy choices available to them.

Ignoring agriculture increased the costs for other sectors and for the economy as a whole, given the abatement costs in different sectors, the communication concluded.

The country’s Marginal Abatement Cost Curve (MACC) analysis was developed by McKinsey and company on behalf of Department of Communications, Climate Action and the Environment.

Its underpinning technology business cases are based on McKinsey’s globally-sourced data on emissions mitigation technologies, which have been localised for Ireland based on extensive engagement with relevant government departments and agencies as part of the preparation of the Climate Action Plan.

Loss-making activities

The Department of Public Expenditure and Reform, alongside the Department of Finance, again raised high-level reservations regarding the agricultural elements of the draft climate action plan in a follow-up communication just 10 days after Watts’ email.

In the additional communication dated April 26 – also seen by AgriLand – the departments jointly stated the following:

As noted bi-laterally, we have some concerns about the achievement and verifiability of the abatement potential identified in the Teagasc work.

If McKinsey can allay some of the concerns we have expressed about particular aspects of the Teagasc work, these concerns may be ameliorated.

However, the lack of analysis on options [regarding] modal shift in the agricultural sector remains a weakness.

At 46% of non-ETS emissions, emissions from the agricultural sector so dwarf everything else that any failure here risks pushing already ambitious targets in the other two key sectors – buildings and transport, beyond believability.

To give a tangible example, McKinsey had referenced (based on the Teagasc work) a 5% cut in the herd as delivering annual emissions reductions of around 700,000 tonnes, which adds up to a cumulative 7 million tonne reduction over the decade. 

The entire €30 billion NDP [National Development Plan] investment programme will deliver cumulative savings of just over double that amount to 2030, if fully delivered on time and on budget.

In contrast, a 5% reduction in herd numbers would take the national herd just back to the level it was at as recently as 2014.

It is accepted that this is easier said than done, but half of all non-dairy cattle farms earned a farm income of €10,000 or less in 2017.

These are loss-making activities, heavily subsidised by the state that only face more strategic risks going forward.

There must be opportunities for policies that can encourage some of these farmers to adopt measures such as extensification, to switch into tillage, forestry and/or energy crops, or even be paid directly for sequestration activities.

This would reduce herd sizes and hence emissions from the sector, while leaving farmers better off. Sooner or later this conversation will have to happen and if presented in the right way it could perhaps be framed in a positive light.

If the choice is made by Government that this cannot be countenanced then further reductions will be required in transport and buildings which will likely be more expensive and likely no less contentious.

If the expenditure isn’t available to support this increased ambition, Government must be aware it will require additional environmental taxes beyond those suggested by the CCAC [Climate Change Advisory Council] and modelled by ESRI [Economic and Social Research Institute] or we will again, likely fail to make sufficient progress towards our climate targets.

If this trade-off is clearly understood by Government we have no issues with it.

Summary: A climate action plan that ignores modal shift in agriculture is not credible. A climate action plan that proposes massive herd cuts is not realistic. However, it must be signalled in this plan that Government will open a dialogue with rural communities to discuss what policies and measures can be developed which could offer alternatives to herd-based systems that would maintain or even boost farm incomes.

In his response to the above communications, Mark Griffin, the secretary general at the Department of Communications, Climate Action and the Environment sent the following on May 30:

“Before the contribution of the NDP [National Development Plan] is taken into account, analysis shows a 101.6MT CO2 equivalent gap to compliance with our 2030 targets.

“The draft plan envisages agriculture closing 45.3MT of that gap – 26.8 Mt (LULUCF) [Land use, land-use change, and forestry] and 18.5 (Teagasc agricultural abatement).

“The draft plan also recognises the longer term requirement to restructure the sector,” Griffin stated.

‘Reckless’

The above documents were obtained by Dublin Green Party councillor for Blackrock, Séafra Ó’Faoláin.

Speaking to AgriLand Ó’Faoláin said the documents “will only reinforce” public scepticism around the 2019 Climate Action Plan, and the Government’s strategy on climate in general.

It is clear that senior civil servants had some serious reservations about the analysis, costing and metrics which formed the foundations of this plan, and that these concerns were willfully ignored.

“It is hard to see how the public can have confidence that the Government’s climate strategy is credible.

“The real-world implication here is that the Climate Action Plan will not deliver the already low target that it promised, namely annual reductions of 3% in carbon emissions.

“This makes multi-billion euro EU fines for climate inaction almost inevitable. Ignoring these looming financial penalties is reckless.

“This Government has signed up to the Paris Agreement and is now showing that is has absolutely no intention to fulfill its commitments. Targets are useless without appropriate policies to achieve them.

“Commitments must be concrete and irrevocable,” he said.