The aim to produce a long-term strategy for the reduction of Ireland’s Greenhouse Gas Emissions to 2050 is welcome.
However, I would like to note at the outset, significant concerns with the way the consultation has been conducted on this critical public issue. These are outlined at the end of this submission. These concerns are relevant to note now because they reflect a significant gap in thinking in terms of how achieving decarbonisation requires innovation both in complex technical as well as social & political systems. Both must be regarded as essential and interacting in order to address the huge social, environmental and economic challenge of climate change and the route to decarbonisation.
The purpose of the consultation is to elicit feedback on ‘decarbonisation pathways beyond 2030, including transition options across all key sectors of the economy (energy, buildings, transport, enterprise, waste, agriculture and land-use), on the role of innovative technologies and on socio-economic factors.’
Pathways and options to deep decarbonisation across key sectors require robust data and models. These aim to produce robust options within highly complex and interacting systems where the future even in the short term is uncertain. What data and models will be used to produce this strategy? In the Climate Action Plan 2019 the Marginal Abatement Cost Curve (MACC model) was developed by McKinsey and Company but is not published or publicly accessible as part of the CAP. The limits of this approach suggest the need for robust and comprehensive real-time models. These could also be used to inform the public both in terms of progress and in supporting consultation and policy development.
In this regard,
there is an opportunity to create a new approach to decarbonisation planning
with this long-term strategy. Specifically,
given the complexity of the issue and the need for large scale public buy-in,
this is an opportunity for a policy innovation that mandates the creation
and open publication of all data required to model future scenarios across
sectors. This is already emerging as an area of innovation across Europe. For
example, real-time anonymised mobile data is used to power new understanding of
transport demand in the Netherlands and as a result, innovations in sustainable
Private sector data on carbon production should be mandated to be open. At the moment it is impossible to know the carbon production of any area. Without the data it is not possible to create or model solutions. Residents of Celbridge, Co. Kildare feel this gap. They are starting to create their own citizen science data on their town to understand pollution and carbon emissions. However, they are unable to access information on the energy use of buildings. This is an important aspect of environmental data that is closed and inaccessible. Communities are mobilising around data. With data in immediate local impacts they can come together with experts, Council (and models where relevant and available) to decide on and take local action to reduce carbon. This local impact that communities own can be a huge lever to mobilising both buy in to change as well as engagement on national level policy for decarbonisation.
Green financing, disclosure
The strategy must not omit the essential role of policy measures to stimulate high-impact private sector action in decarbonisation. Green Finance must become the default of the public sector in terms of insurances and pension finance etc. A key strategy should be mandatory disclosure of company and public body investments in fossil fuels. These are high impact measures that can stimulate both private and public sector action creating potential synergies.
The importance of investment in modelling cannot be overstated. We need to scale Ireland’s research capacity and Ireland’s policy makers must respond with action to high impact findings of these research bodies. For example, ESRI’s research point to the impact of -20% carbon emissions by 2030 in reducing a range of fossil fuel subsidies, including in transport and peat production sectors. Modelling the impact of fossil fuel investment disclosure would provide new information to drive further adaptive decarbonisation responses.
Anyone solution while positive in one area can have multiple impacts. For this reason, pathways development must involve a complex research driven approach with system innovation thinking. In research on Australian land-use Bryan et al. (2016)  show ‘that strong potential future land-use and sustainability responses were possible. However, the exact nature of these responses and their magnitude, in addition to where and when they might occur, was sensitive to global outlook and the strength of the global emissions abatement effort, domestic land-use policy, and key uncertainty dimensions including land-use change adoption behaviour, productivity growth assumptions, and capacity constraints.’
Ireland requires large scale investment both in carbon-reducing activities and also in the research, data and modelling capacity that we need to ensure that potential unintended consequences can be known and mitigated; and that we can maximise efforts to those pathways that generate the most impact. It is encouraging to see the accessible findings of the marine and renewable energy research, development and innovation Centre (MaREI) in UCC. Their research on ‘Opportunity for Ireland in a Low Carbon Economy – our 2050’ demonstrates both positive knowledge transfer between research and policy-making – as well as doing so in a way that is accessible to the public.
Policy on climate change adaptation, mitigation and deep decarbonisation cannot be advanced in the absence of data, science and modelling. We need as part of the long-term strategy to develop world-class leadership in this area.
Recommendations for decarbonisation by 2050:
- Accelerate a new national programme of carbon-product data collection from local to national level
- High investment in R&D on dynamic models and knowledge gaps in policy and practice needs
- Mandatory production of data on carbon-producing products by companies to power models
- Disclosure of investments in fossil fuels by companies and public bodies
- Accessible public communication on national and local climate research & progress with access to models
- Mainstream system innovation thinking through strategy development and communication on climate change and decarbonisation
The social transition to a net zero-carbon future by 2050 will by necessity bring political change as citizens drive the decisions-processes that bring us to 2050 through elections, engagement in and evaluation of decisions. The strategy is less likely to work where it is developed from the top-down. There is an opportunity with open knowledge, local funding and mobilisation to co-produce in a meaningful way, Ireland’s transition.
At the very minimum, there needs to be a
major improvement in public consultation practice. This consultation showed the
gap that needs to be addressed at the most basic level. For example, it does
not comply with principle 3 of the Gunning Principles, with not enough time to
respond to such a complex and important consultation. In addition, the
consultation was held over the Christmas holiday period.
It is also not clear how feedback be used apart from ‘considered’. What are the criteria against which feedback will be considered? What is the decision process, who are the decision makers? This is key information that also needs to be shared as part of best practice public consultation.
The consultation should also have presented more contextual information for the public in the form of an issues paper. The context of the questions should also have been set out as well as the purpose of the questions with respect to the final strategy document. The audience for this consultation was not clear. To what type of audience were such complex questions were addressed? There are many different audiences and stakeholder groups, and this should be factored into consultation design and planning in order for a meaningful contribution to be possible from all sectors to this important strategy. There is an opportunity to develop a consultation charter that embody the Gunning Principles and set the framework for a well-planned and meaningful consultation in the form of a consultation charter.
Within the broader context we need to move towards a deliberative democratic system from the local to national level, where citizens knowledge, experience and problem-solving capacity are brought meaningfully into planning and policy making. Public deliberation should be advanced at the local level linking to national policy and deliberation on climate and other social issues.
In this respect, there is also a need to develop more advanced ways to understand public opinion. Surveys and polls are no longer enough to understand shifting and nuanced public opinion. There are new methodologies that have been shown to be highly effective way to obtain deep understanding of the public opinion for transparent and inclusive public deliberation as shown in the Netherlands, Australia and the US. An example is already demonstrated at the local level at yourairportviews.fingal.ie using Q-methodology.
Finally, in the context of the role of open local data in mobilising communities and its role in co-producing sustainable actions and policies for the rapid transition needed, it is essential that Ireland meets its obligation to deliver its third Open Government Partnership National Action Plan. This is currently one year late. These structures, partnerships and civil society networks are already in place and the value of OGP must be acknowledge and mobilised as part of the process for opening knowledge, policy and planning processes that are key to both the immediate and long-term strategy for our decarbonisation and social transition.
Recommendations for decarbonisation by 2050:
- Establish Gunning Principles and Consultation Charter for effective public engagement in policy and planning
- Use more advanced, democratic and transparent ways to understand public opinion
- Support and enable deliberation at local level with move towards a meaningful deliberative political system
- Deepen engagement with the OGP process and meet obligations
Thank you for your consideration of the points raised in this submission.
Cllr. Vanessa Liston
email@example.com | 086 1408681
Submitted: 31st December 2019