'A significant unneccesary burden on economic activity'

Letter from ICMSA President Jackie Cahill to TDs and Senators regarding Climate Change Response Bill

Letter from ICMSA President Jackie Cahill to TDs and Senators regarding Climate Change Response Bill

Dear Deputy,

We are very concerned that the Climate Change Response Bill 2010, if enacted, would impose a significant unnecessary burden and restriction on economic and other activity in Ireland over and above what was legally required of Ireland under EU and international agreements.

Let me first of all emphasise, ICMSA and farmers generally are fully committed to a low carbon footprint sector and indeed the records show that agriculture has reduced it emissions from 20.9 MT (million tonnes) in 1995 to 18.4 MT in 2008.

However, there is a limit to what our sector can do in terms of further reductions and indeed the realisation of the Food Harvest targets for increased output in the agri-food sector, particularly in the dairy sector by up to 50 percent must be taken into account.

Unfortunately the target set in the current Bill takes no account of these critical and important national economic matters.

While there are currently EU legally binding obligations on Ireland with respect to emission figures for 2020, further negotiations are imminent post the Cancun Accord on Climate Change.

This is almost certain to involve negotiation about the distribution among Member States of the increased reduction burden which the EU has now apparently taken on board. These negotiations will be of vital national importance.

Unfortunately, the targets in the Bill not alone fail to address these matters, but the Bill, as currently proposed, could actually limit or totally undermine the negotiating position of Ireland to obtain a favourable burden sharing arrangement of EU commitments.

It will be recalled that with regard to the current 2020 binding commitments for the non trading emissions (non-ETS) Ireland, with some other Member States, had to take on a 20 percent reduction relative to the 2005 figure, while some other countries have lower reductions placed on them to achieve the overall EU reduction commitment.

During the course of the discussions and negotiations, Ireland rightly advanced the argument that our emissions profile was quiet unique giving the dominance of farming in Ireland's emissions compilation.

Agriculture currently accounts for 39 percent of non-ETS emissions in Ireland. Significantly, normal farming activity (i.e. enteric fermentation or bovine digestion and regular husbandry activity) accounts for 95 percent of the total emissions attributable to agriculture. Fossil fuel combustion including diesel accounts for just 5% of emissions.

Ireland must renew this argument with respect to our unique emission profile with greater vigour at EU level given that a new binding reduction of 30 percent is set to be adopted by the EU.

The imputed emissions profile of the agricultural sector is due in large part to natural processes rather than a heavy reliance on fossil fuels. It is against this background that the Climate Change Response Bill must be seen as a hindrance and a significant danger to our negotiating stance.

Given the current position and particularly in advance of further probable negotiations with our EU partners, Ireland should not incorporate any target in legislation at this time. There is nothing to be gained from this at this stage other than undermining Ireland's negotiating position.

The targets set out in the Bill go beyond what is required and would require a significant reduction in economic activity and or a recurring annual cost in the form of an increased requirement to purchase carbon emission credits. Ireland, given its present precarious economic position must be resolute on this matter.

Rather than taking on an increased burden, the focus must be on insuring that any increased obligations at European level do not lead to an increased obligation on Ireland. This Bill is not alone of no value in this regard, it is patently detrimental.

In conclusion, it is our considered view that the Bill in its present form should not be proceeded with or that in any event there should be no target figures incorporated in the legislation.

Yours sincerely,

Jackie Cahill

President

ICMSA