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An Taisce The National Trust for Ireland

ATNTI

An Taisce is The National Trust For Ireland - it is - 'The Store House, or Treasury' An Taisce is Ireland's oldest environmental charity founded over 70 years ago to protect the environment and heritage of Ireland for the benefit of the people of Ireland and future generations and for the ‘Common Good’. We believe that this is best achieved through sustainable development, achieved by a long term and planned balance of social and economic development with environmental protection. An Taisce is a member of INTO - the International National Trusts Organisation a large global movement of approved National Trusts which preserve and hold property in perpetuity for the benefit of their respective peoples. An Taisce acts as an impartial monitor in Ireland on the application of EU environmental legislation at local level. An Taisce reviews planning applications within the context of the requirement to meet EU Directives An Taisce provides evidence to Government on the performance of local authorities in delivering the provisions of the various Planning Acts and Regulations. An Taisce acts as a key Consultation Prescribed Body under Section 24 of the 2000 Planning and Development Act for input into national policy formulation. An Taisce’s network of Local Associations and 5,000 members mirrors many elements of the Local Agenda 21 model. An Taisce supports its members and network of Local Associations by facilitating a bottom-up consultative approach when making submissions on national or local planning policy. An Taisce responds to consultation requests on an on-going basis. An Taisce promotes environmental awareness through Green Schools and other educational programmes. An Taisce are heavily involved in promoting the UN SDGs An Taisce are members of: The International Union for the Conservation of Nature (IUCN) European Environment Bureau Europa Nostra Foundation for Environmental Education (Green Schools/Green Flags Blue Flag etc)

Lobbying Activity

Response to Union inventory system, global warming potentials and internationally agreed guidelines to be used in reporting

1 Apr 2020

Updating the values of the global warming potentials (GWPs) used in EU greenhouse gas accounting to match the most recent full IPCC AR5 assessment is long overdue – Working Group 1 reported six years ago – and is clearly necessary. However, the proposed Delegated Act fails to align with the Paris Agreement to undertake mitigation using "best available science" in two important ways as described below. This means that the Act and Annex now need to be redrafted as a matter of urgency. First, the Delegated Act states that, "The proposed values of global warming potentials in the delegated act in question are based on the 5th Assessment Report of the Intergovernmental Panel for Climate Change, in line with the latest science." This is only half true, and it leaves out the half that is actually the 'best available science'. The GWP100 values given in the Annex for CH4 and N2O are as in Table 8.7 of AR5 WG1 Ch. 8 which are the lower values, of 28 and 265, respectively, with "No cc fb" [No climate-carbon feedbacks"]. Our question, from An Taisce and from climate research at Dublin City University (DCU), is: Why does the Delegated Act fail to mention the higher "With cc fb" values for CH4 and N2O of 34 and 298 from the same Table, that are, scientifically, more appropriate to policy? It is not acceptable to simply choose the lower values when the IPCC are clear that the feedbacks are important and senior experts in climate science make it very clear that climate-carbon feedbacks are very real and must be included, as they are entirely relevant to aligning policy with the Paris Agreement. For example, climate scientist A. Reisinger in advice to the New Zealand government, states that "information [on methane's effect without climate feedbacks] is provided for completeness only, since climate-carbon cycle feedbacks are undoubtedly a part of the climate system." p.33. https://www.pce.parliament.nz/media/196482/contribution-of-methane-emissions-from-nz-livestock-to-global-warming.pdf It is therefore not acceptable that the Delegated Act fails to acknowledge this science and it is scientifically incorrect in terms of climate action policy to use the GWP100 values with no climate-carbon feedbacks when the science plainly indicates that these feedbacks are critically important for policy. On this basis, the Act needs to be redrafted to reference the GWP100 values "With cc feedbacks" values in the Annex to the Act. Second, GWP100 is inherently flawed in that it cannot register the reality that methane reduction can cause a reduction in methane concentration and enabling warming reduction. GWP20 also fails to register CH4 warming reduction. Such methane warming reduction (equivalent to negative emissions) is now critically important to maximising CO2 budgets, therefore it is essential to account for it. See IPCC SR15 SPM Figure 3.a showing extent of CH4 reduction for Paris pathways. The use of the recently developed GWP* metric, based on GWP100 should be considered to account for methane warming reduction and to show the extreme warming due to increased CH4 emissions. However, as detailed above the 'with c-c feedbacks' GWP100 values are scientifically recommended for use, including for use with GWP*. Our research at DCU (EPA-funded report just submitted) finds GWP* is not appropriate for single sector (eg agriculture only) or short-term/annual analysis. Moreover, at UNFCCC level any change from GWP100 accounting may have serious equity issues (DOI 10.1088/1748-9326/ab4928). Nonetheless, use of GWP* is appropriate to use for comparison of the aggregated-GHG, cumulative CO2 warming-equivalent (CO2-we) contributions of alternative national or EU long-term scenarios to meet Paris targets, to include CH4 and N2O with CO2 in cumulative carbon budget. See slides: https://tinyurl.com/IE-SSECCM-seminar-slides-2020 We strongly request that the European Commission reconsider and reissue this Delegated Act given the above serious issues.
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

In its findings and recommendations adopted in 2011 and 2017 with respect to communication ACCC/C/2008/32, the Aarhus Convention Compliance Committee (ACCC) concluded that the rules on standing, laid down in Article 263(4) TFEU, to directly challenge acts and omissions of EU institutions do not comply with Article 9(3) of the Aarhus Convention (AC). With respect to the internal review procedure under the Aarhus Regulation, the ACCC found the requirements that the ‘administrative act’ challenged be of “individual scope”, “adopted under environmental law” and “have legally binding and external effects,” as well as other aspects of the regulation, fail to comply with the Convention. Such requirements have created significant barriers to accessing the internal review under the Aarhus Regulation, with only 20% of cases being declared admissible. In 2017, the ACCC recommended that the EU amend the Aarhus Regulation (or adopt new legislation). The AC, to which the EU has been a Party since 2005, is an integral part of the EU legal order and is vital to bolstering European citizens’ environmental rights. It is therefore essential that the EU legislature moves to amend the Aarhus Regulation to bring the EU into compliance with its obligations under the AC. While the European Commission initially proposed that the 6th session of the Meeting of the Parties (MOP) in September 2017 should “reject” the ACCC’s findings of non-compliance, the Council ultimately adopted a decision to “take note” of the findings. The refusal to endorse the findings of ACCC has been a source of great concern and disappointment, ending the long-standing practice of the Aarhus Parties “endorsing” all findings of non-compliance by consensus. The EU was not supported by other parties some of whom voiced concern that the EU was seeking to obtain a special status, a status that would be neither politically nor legally defensible. This clash has resulted in the matter being postponed to the next MOP in 2021. In the intervening months, the Member States have realised that this sets a poor precedent and that the EU cannot avoid performing its duties under international law, as illustrated by the intent of the Council to make an official request based on Article 241 TFEU to the Commission asking them to adopt a legislative proposal. The European Parliament and the European Economic and Social Committee have also called for the the Commission to comply with the findings of the ACCC and to revise the Aarhus Regulation. Against this backdrop, it is now timely for the Commission to remedy the incompatibility of its acquis with the AC by amending the Aarhus Regulation. In sum, it is the view of An Taisce - the National Trust for Ireland that the EU, as a party to the AC in its own right and as a party in non-compliance, must remedy this situation with immediate effect. An Taisce further asserts that the EU is not entitled, pursuant to article 27 of the Vienna Convention of the Law of Treaties, to avoid performing its duties under the AC by invoking provisions of its internal law. It follows that the only way to remedy this violation of international law is for the European Commission to propose amendments to the Aarhus Regulation that would give full effect to its obligations under the AC. Contact: Philip Kearney, Chair, Climate Change Committee An Taisce, The National Trust for Ireland mobile: +353 (0)86 2659833 email: climatechair@antaisce.org web: http://www.antaisce.org/topics/climate-change
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Response to Evaluation of the impact of the CAP on climate change and greenhouse gas emissions

6 Jul 2017

Please see full text attached. An Taisce (The National Trust for Ireland) would like to provide feedback in relation to three main points: 1. The CAP in its current form promotes unsustainable, carbon-intensive agriculture in Ireland. 2. Sequestration in forestry should not be used as a substitute for the reductions required from livestock emissions in Ireland. 3. Beef and dairy production in Ireland would be a highly relevant case study for this evaluation given the significant emissions from this sector. 1. Irish agriculture and climate change ● In the strategic plans Food Harvest 2020 and Food Wise 2025 , the Department of Agriculture, Food and Marine (DAFM), claims that Ireland will play a key role in meeting global demands for food, while overcoming the challenges of food security and mitigating climate change, through increasing beef and dairy exports to EU markets and increasingly to international markets. ● These claims are scientifically ill-founded and seriously misleading. Both the EU and Ireland are net importers of food calories . Imports and growth of feed for livestock undermine global food security by reducing the land available for growing human-edible food . Beef and dairy products are highly GHG-intensive, yet inefficient in producing protein . The CAP needs to be redesigned to support less wasteful and less climate polluting food. ● Due to the social and economic prominence of agriculture in Ireland, and the predominantly grass-based nature of Irish agricultural production, the Irish government, supported by industry and lobby groups, argue that Ireland should receive special treatment with respect to the allocation of climate targets for 2030 within the EU. ● Although the agri-food sector contributes to the economic viability of Irish rural life, and is cited as being one of the most important indigenous manufacturing sectors in Ireland, the sector, particularly in beef and dairy, contributes significantly to Ireland’s greenhouse gas emissions profile. ● Agriculture remains the single largest contributor to the overall greenhouse gas (GHG) emissions in Ireland, at 33.1 % of the total . Emissions from agriculture increased by 1.6% or 0.32 Mtonnes of CO2eq in Ireland in 2015. The most significant drivers for the increased emissions in 2015 are higher dairy cow numbers (+7.7%) with an increase in milk production of 13.2%. This reflects national plans to expand milk production under Food Wise 2025 and the removal of the EU milk quota in 2015. ● Agriculture and Transport are projected to account for 74% of Ireland’s non-ETS sector emissions in 2020 (agriculture: 45%, transport: 29%) and for the period 2015-2020, agriculture emissions are projected to increase by 4–5%. It is becoming evident that Ireland will fail to meet its target to reduce non-ETS emissions by 20% by 2020 compared to 2005 levels. ● The agriculture sector in Ireland is propped up by large economic subsidies, such as the agricultural product subsidy for cattle (totalling €42.5 million in 2015), which have been labelled as potentially environmentally damaging. ● In 2016, Irish dairy farmers experienced significant financial losses as a result of market volatility in milk prices, underpinned by over-production and a surplus of produce on international markets. Over-production has resulted in the return of EU storage intervention schemes and low prices for farm produce. This calls into question the sustainability of Irish beef and dairy production which accounts for significant GHG emissions and is incentivised by CAP subsidies. ● Experiences of financial loss among farmers, arising from market volatility calls into question the viability of the current model of the CAP. An Taisce’s position is that farmers should be supported by EU policy to maximise calorie and protein production while minimising impacts to climate and the environment in Ireland and elsewhere.
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Response to Changes to greening rules and clarifications of certain other direct payments' rules

11 Jan 2017

It is widely accepted that agricultural intensification is the greatest driver of terrestrial biodiversity loss in Europe. The need to reduce the environmental impact of agriculture in Europe is the most important action the EU must take to tackle the ongoing global mass extinction event being driven by humanity. The CAP has a budget of 58 billion Euro a year, which accounts for about 40% of the EU’s total budget. Under ‘greening’ it was agreed that 30% of EU countries' direct payment budgets or 12 billion euro a year would be reserved for certain practices aimed at addressing biodiversity loss, avoiding crop monoculture and securing carbon sequestration. Ecological Focus Areas were introduced as part of the ‘Greening' of the EU’s Common Agricultural Policy (CAP) under the 2013 CAP reform. EFAs were established ‘to safeguard and improve biodiversity on farms’ as per recital 44 of Reg.1307/2013 “by boosting natural processes and so strengthening the ecosystem functions that are essential for the long term productivity and intrinsic fertility of our food production systems.” The use of pesticides in EFA's fundamentally destroys the ability of these areas to host natural processes or to carry out ecosystem functions. This practice critically undermines the credibility of 'greening.' EFAs which cannot support life do not contribute to the conservtion of biological diversity in the EU in any way and are a waste of taxpayers money. Any efforts to tackle biodiversity loss under the CAP must be commensurate with the scale of the threats/pressures facing habitats and species associated with agricultural systems. It is clear that even banning pesticides in EFAs will not be enough to achieve the EU's 'No Bet Loss' objective by 2020 but it is certainly a start. If greening fails then the CAP's budget must be called into question.
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Meeting with Miguel Arias Cañete (Commissioner) and Greenpeace European Unit and

13 May 2016 · EU energy and climate agenda for 2016