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  • Martin Hawkes

    Comments on Draft National Mitigation Plan

    General comment
    It is good to see the setting out of the facts of where we are and an acknowledgement of the short-falls that are likely from both our 2020 commitments and the obligations that are likely to accrue in the 2021-2030 period. Quantifying our obligations in carbon budget terms allows for a clear understanding of the magnitude of the task ahead and this is very positive.
    Also on the positive side is the commitment to an all-of-Government approach and the intention that the NMP be a dynamically evolving document, a work-in-progress available on the department’s web-site. Likewise the exposition of the current state of play in relation to emissions, policy measures and issues within the energy, built environment, transport and agricultural sectors is welcome. That DCCAE is the central department responsible for pulling it all together is also welcome.
    What is difficult to understand is the apparent lack of ambition to articulate a suite of actions that might logically follow from the factual exposition. In particular there appears to be a failure to relate the costs of inaction – even the purely financial penalties attendant on BAU – to the need for action now. While, for example, there must be a proper concern with the PSO levy, this must be matched by an equal concern for the penalties and resulting imposition on the general tax payer that will attend our failure to meet our targets. Surely it makes more sense to invest in our own national and community capacity now than waste scarce resources on probable penalties later? Nowhere do these trade-offs appear to be considered.
    We are at a time of profound change in societies world-wide. The locus of initiative is shifting increasingly to the bottom-up as a result of the failure of political systems to adequately respond to challenges that are long-term, systemic and complex in nature – and not easily accommodated within the time-lines of electoral politics. Climate change is but one of the most obvious of these challenges. And yet, despite the apparent awakening in the 2015 Energy White Paper to the centrality of social actors, this realization seems relatively mute in this document. In so far as the energy sector is concerned one senses that the citizen and local communities must be engaged as a problem to be circumvented rather than as a key resource and solution to the challenges of both mitigation and adaptation.
    As the NMP is presented as a dynamically evolving document perhaps future iterations will interrogate the framing assumptions; is the process informed by a traditionalist incumbency mind-set or is it open to reconceptualising the way policy-formulation is informed by a deeper and more genuine engagement and co-creation with wider society? Communities are a key resource in addressing both mitigation and adaptation and public policy needs to be framed as if this insight were truly grasped. This requires investment in longer-term social capital formation, for which the short-term financial efficiency criteria are inadequate.
    In addition an approach to climate change characterised by expediency – if it fits within the EU framework it’s OK whether or not it is sustainable in a wider context – needs to be replaced by a philosophy that recognizes the true nature of the challenges that confront us. Only when public policy is framed as if climate really mattered to us independent of EU obligations will we get the ambition and creativity to match the reality of the historic challenge.

    Energy Sector
    • Coal & Peat Fired Stations: the lack of any clear plan for the phasing out of coal and peat feels like the elephant in the room. That the PSO levy should continue to subsidise peat up to 2019 is surely an anachronism. That this can be replaced by a REFIT to support biomass which is imported unsustainably is surely expediency, not mitigation? Likewise the paper reveals the extent of the increase in recent years of coal-burning at Moneypoint – a cheap polluting fuel that underpins payment of dividends to the Exchequer. The document is silent on the Moneypoint transition from its current configuration in 2025 but it’s hardly a secret that, like peat-burning stations, the biomass option is under active consideration – again, one assumes, relying on the importation of unsustainable biomass and with the possibility of a public subsidy? The public surely deserves to have clarity on, and be involved in the formulation of whatever plans are envisaged for the operation and subsidising of these public utilities.
    • Question 1: With the need to transition our transport and heat systems to clean green electricity the plans for RE need to be ambitious and a clear vision and road-map need to be set out. It’s positive that the capacity of the grid to take non-synchronous electricity is set to increase to 75% by 2020. Within the massive increase in RE that will be needed it is difficult to understand the reluctance to facilitate a roof-top revolution in PV by allowing private generators to sell into the grid. This is where a bigger vision than the short-term cost-benefit analysis of what is required by our 2020 targets is needed. Yes, we can meet 2020 RE targets without facilitating roof-top and the operation of the ETS may result in no net carbon saving in the global system in the short-term but, if we want to bring the prosumer on a longer-term learning journey of engagement with the energy transition, we must be ready to prime the pump of individual and community involvement. Why are we willing to charge a PSO levy to subsidise polluting peat, unsustainable imported biomass and commercial wind energy but set our faces against domestic rooftop? The rationalisation that this would be socially regressive appears to be just that, a rationalisation of an unwillingness to enable a decentralisation of power generation that would build much greater resilience into the system and mobilise communities. Priming the pump requires supporting those willing to be early-adopters and risk-takers. (Preferential subsidies for the energy-poor for retrofitting their houses can deal with any genuine social equity concerns). Electricity utilities can be the enablers of the future by financing rooftop through energy buy-back schemes or run the risk of being over-taken by PV and battery technology that will make households self-sufficient in power in spite of the incumbents i.e. be part of the solution or run the risk of becoming obsolete.
    • Q2: See 1 above. If RE is to power transport and heat, public policy needs to engage households and communities in prototypes that give them some ownership of the greening process.
    • Q3: Ditto: when communities sense real partnership/ownership of the bigger system they will come on board – if they sense the bigger system is being imposed where they bear the environmental costs but don’t share the benefits, they will view developments in a negative light.
    • Q5: See 1 above. Framing questions in short-term efficiency and effectiveness terms misses the wider social calculus needed if seeking to invest in social capital formation for the longer-term.

    Energy Efficiency in the Built Environment
    • Q1-Q3: As with RE there is a need for a road-map of the transition to a retrofitted housing stock. The €31m funding accorded the SEAI to support BEC schemes is not sufficient to even scrape the surface of the task though it may facilitate some limited prototyping. The investment required in retrofitting the housing stock runs to €billions on an annual basis. A funding model is essential. How might pay-as-you-save models work? Might the Government create a cheap loan scheme through the banks and credit unions to facilitate investment in retrofitting? Whatever the solution the issue requires urgent and committed attention if investment on the scale required is to be undertaken.
    • Q4: The pay-back on PV (and heat pumps) and such like is not attractive at present. However, if prosumers could sell their excess electricity into the grid this would change the calculus somewhat. Furthermore if the ESB and utilities were to fund investment in roof-top in return for buying back the excess power a win-win solution could be created. What’s required at this early stage of the game when battery (and PV) technology are still evolving is to invest the necessary resources in getting communities and individuals encouraged to become leaders and exemplars for others.

    Transport
    • Q2: There is need for an ecology of supports to encourage adoption of EV’s – dedicated charging point stations, easy installation of charging points at houses, access to bus corridors, preferential parking and toll-free motorway access. The ‘stick’ approach of gradually making conventional motoring more costly as EV’s become more practical as an option (i.e. battery range issues resolved and easy charging facilitated) is worth considering.
    • Q3: Urban and town planning needs to make it easier and safer to transition to bikes and battery-powered bikes, a potential game-changer – as well as public transport which, itself, needs to be greened. Public policy needs to: (i) promote the established co-benefits to health of cycling; (ii) develop more dedicated cycle paths/lanes; (iii) support car-sharing schemes.

    Agriculture, Forest and Land Use Sector
    • Q1-2: As with the draft NMP in general there is a need to look at the cost consequences of the policies we’re embarked upon in a joined-up fashion. At best we are informed that emission from this sector are going to creep back up to 2005 levels and carbon neutrality appears to be the limit of ambition. In an era when farm systems such as the suckler beef are dependent on income support it seems more rational to look to RDP to supply an approach that better reconciles the needs of farmers and rural development with environmental sustainability.
    • Q3-4: Following on from the foregoing logic farmers need to be rewarded for farming in a manner that better accords with environmental sustainability. Every farm, indeed every field, has the potential to deliver ecological services from carbon sequestration, water management, food production, fire-break provision, bio-diversity etc. Optimising land-use according to the eco-services provided affords a frame of reference that reconciles what is best for farmers and the rural community with what is best for society and the environment. The methodology for such an approach has been pioneered by Burren Life whose scoring approach to eco-services outputs has been recognized at EU level for its cost-effectiveness. While the Burren context is unique Burrenlife’s simple and highly-effective methodology is transferrable to other regions and farming contexts. (BTW Burren Life has just been adjudged among the top 5 of the 4,300 Life projects in the EU over the past 25 years).
    • Q5. See above – the Burren Life approach to working with farmers is a model for how to engage and empower farmers as the custodians of the landscape.

    MH
    25/4/17

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