Ireland’s climate action plan 2024 – a welcome step but delivery issues remain

CAP 24 is the third iteration of Ireland’s annual update regarding climate related policies and strategies.  Ireland’s climate governance and reporting framework is informed and guided by the obligations and requirements set out in related EU legislation and regulations, including the European Green Deal, the European climate law 2020, and the European Commission’s REPowerEU plan.

The targets set out in CAP 2024 remain largely the same as under the 2023 plan. However, CAP 2024 builds upon previous plans by refining and updating the measures and actions required to deliver the economy-wide carbon budgets and sectoral emissions ceilings introduced by the Irish government in July 2022. The annex to CAP 2024 sets out specific new, high impact actions for the 2024 targets to be achieved.

While the plan is subject to a public consultation and strategic environmental assessment, which may lead to adjustments ahead of the anticipated publication of the final version this spring, businesses can get a sense of forthcoming changes in regulation and policy from what is detailed currently. The public consultation opened for submissions on 20 February 2024 and runs until 5 April 2024.

Among other things, the Irish government has said it will:

• adopt the electricity storage policy framework, incentivise and enable large energy users to join flexible demand initiatives, publish revised wind energy development guidelines for onshore wind, and deliver onshore and offshore Renewable Electricity Support Scheme (RESS) auctions as per the annual RESS auction calendar;
• develop a work programme to implement the national hydrogen strategy and implement the decarbonisation roadmap for industrial heat based on the recommendations of the Sustainable Energy Authority of Ireland’s national heat study
• publish the ‘2030+ Roadmap’ to determine pathways for deployment of offshore and ocean technology. It will involve producing technology scenarios, conducting stakeholder consultations, and identifying suitable policies and the appropriate regulatory environment;
• develop green skills and capacities required for a ‘net zero’ economy through education and training boards;
• progress the development of a proposal for an offshore renewable energy innovation park. This will include a proposal for a designated maritime area plan, the exploration of options for grid connection and access routes, as well as a suitable operating model. The ORE Future Framework consultation has already been published in 2024.
• develop a private wires policy framework by the final quarter of 2024. The consultation is currently under review and responses are expected shortly;
• create a route to market for medium and long duration - four-hour-plus – storage facilities to support low-carbon generation;
• establish a biomethane coordination group to oversee the delivery of the target of supplying 5.7 TWh of biogenic methane by 2030, in line with the national biomethane strategy, and identify appropriate KPIs and the underlying monitoring and reporting process, in the first quarter of 2024. On 30 January 2024, the government opened its consultation on Ireland’s draft national biomethane strategy.

CAP 2024 aims to close the emissions gap and sets ambitious climate action targets for delivery on Ireland’s climate goals. However, as per the quarterly progress reports available on DECC’s website, the implementation of these targets has historically been slower than envisaged. The progress reports show that 78% of targets due by end-2020 had been delivered on time, for 2021 and 2022 these figures were 66% and 79% respectively. The Q4 progress report for the 2023 hasn’t been published but up to Q3 2023, an overall implementation rate of only 67% had been achieved.

The Q3 2023 plan progress report details that the main issues causing the delivery delays include capacity constraints, including resourcing, procurement issues, legislative delays, the layers of administrative clearance required, and the time taken for stakeholder consultation. With delivery of actions from previous climate action plans often being delayed and Ireland’s history of missed climate action targets, it is important that the measures set out in CAP24 are implemented at greater speed and scale.

Although the climate action plans are a welcome step in the right direction, resourcing and delivery issues need to be addressed in order to fully implement existing measures as well as new actions and policies set out in CAP 2024.

Co-written by Shani Stallard and Isabel Humburg of Pinsent Masons.