Summary
With the recent publication of Ireland’s 2021 Climate Action Plan we have taken a look at what’s inside to give you this EcoMerit Review of the plan.

The Positives:
The 2021 Climate Action Plan is a considerable improvement on anything which has come before, including the 2019 Climate Acton Plan. Overall the targets are more ambitious and more in line with what is required to get us on track.
The fact that it is underpinned by legally binding commitments is important- there is a legal mandate to actually carry out this plan (or at least to make a serious effort- more on the practical likelihood of fulfilling some points in the plan below.)
Money is being made available to carry out the plan. The 2021-2030 National Development Plan claims to have a strong emphasis on climate action, with money being allocated towards actions required by the Climate Action Plan. For example:
- DECC funding trebled to €12.9bn over the period
- €5bn assigned towards increasing energy efficiency
- Continued government support for the RESS (Renewable Electricity Support Scheme) estimated to provide €7.2bn to €12.5bn in supports to incentivise private capital investment to deliver on the Climate Action Plan target of 80 per cent renewable electricity generation by 2030.
The Negatives:
The plan still falls somewhat short in terms of the deep structural change required to stay below 1.5 degrees warming and truly rising to the challenge of climate change and ecological breakdown.
This is illustrated by the recent Climate Action Tracker projections which estimate that even if all NDCs (National Determined Contributions, i.e. national pledges and targets such as those made at COP or in National Climate Action Plans) are fulfilled , global temperatures are still likely to surpass a 2 degree increase.
Climate Action Tracker Thermometer

While Ireland’s Climate Action Plan is ambitious in some areas compared to the rest of the world (e.g. 80 per cent renewable electricity generation by 2030), in other areas it has been criticised for falling short (e.g. while Ireland joined 105 countries in pledging a 30% reduction in methane emissions, the Climate Action Plan is notably silent on how this is to be achieved)
The biggest areas of concern, from an EcoMerit and human perspective are as follows:
- The plan for a ‘Just Transition’ only applies within Ireland. It ignores our international moral obligations, i.e. that rich countries such as Ireland should be doing proportionately more than poorer countries which typically will bear the brunt of climate change and are less able to respond.
- The SME sector, except for large energy users, exporters and high growth potential businesses (Enterprise Ireland clients) seems to be largely ignored. We know that SMEs are capable of making a major contribution to Ireland’s climate change objectives, given the right supports. According to this study, 70% of EU industrial environmental damage comes from SMEs, therefore addressing this sector appropriately is going to be key to addressing the climate impact of industry.
(NB: The current plans for SEAI Communities grants already seem to reflect this negative policy) - The actions for public transport seem to lack ambition. 15 years to electrify the major cities’ bus fleets. Only 100 km of new rail electrification. Delaying until 2022 a mandate for new public vehicles to be zero-emissions where practical.
- Some of the expected outcomes seem to be unrealistically optimistic, e.g.
- 845,000 electric vehicles (EVs) on the road by 2030. This implies around 80% of all new car sales from now on will be EVs. In 2020 it was 8%.
- 500,000 housing retrofits to B2 standard. This implies over 50,000 per year. In 2020 it was 4,000.
- 4Mt of savings from unspecified sources and a further 0.9 Mt of unspecified transport savings.
Detailed Breakdown of Climate Action Plan 2021
Here is a more detailed breakdown of the plan, pointing out some of the key points and giving our analysis:
Page | Comment |
21 | Buildings Energy Efficiency: ‘One Stop Shop’ applies to commercial as well as residential energy upgrades (implied as already in place). |
23 | 4 MtCO2eq reductions left unallocated for emerging actions and technologies. Seems rather optimistic. |
28 | Target of 845,000 EVs “with a focus on BEVs” – but doesn’t state what % is expected. This will have a major impact on effectiveness. Hybrids perform much more poorly that BEVs. Very woolly. 500,000 domestic B2 retrofits. Is this achievable? Only 4,000 in 2020. 400,000 zero emissions heated homes. Is this realistic? |
74 | “We will transition public bus fleets to zero emissions models though the renewal and expansion of the fleet, allowing for the full electrification of double-decker buses in Dublin, Cork, Waterford, Limerick and Galway by 2035.” Why not much faster? |
74 | Trebling the length of the electrified rail network from 50 km to 150 km by 2030: Committing to add 100km of rail in 9 years seriously lacks ambition. |
74 | The Office of Government Procurement will develop and implement a sustainable public procurement policy and update all procurement frameworks, in line with green procurement practice by 2023. We have supposedly had green public procurement for the last 10 years. Needs a lot more than a new framework |
74 | We will mandate the purchase of zero-emission electric vehicles where available and operationally feasible by end of 2022. Why not now? |
83 | We will continue to scale-up and improve the Sustainable Energy Communities programme and seek to enlist a wider range of organisations. . . (The new 2022 policies are making it harder for organisations to participate, The EcoMerit Community has been has been campaigning on this over the last year) |
95 | It will be essential to deliver at least 2 GW of additional gas generation capacity by 2030 to ensure security of supply, underpin our increased renewable targets, and give investment certainty. Fine if this is green hydrogen or renewable gas, not so good if it is fossil gas. Shouldn’t this be specified as a priority or an expectation? |
95-97 | A lot said about the need to balance electricity capacity and demand, very little said about how this will be achieved, except for increased gas powered generation. Surely we should be specifying vehicle-to-grid as something which need to be prioritised. Maybe also electrical storage capacity. |
104 | Enterprise – It is clear that policy measures to date will not achieve the level of decarbonisation now required in the industry sector, which is a reduction from 7.9 MtCO2eq. in 2018 to approximately 5 MtCO2eq. in 2030. (It then proceeds to pretty much ignore the entire SME sector except to provide an ‘online Climate Toolkit 4 Business’. Disappointing) |
107 | “Our National Recovery and Resilience Plan prioritises advancing the green transition. We will: • Accelerate decarbonisation of the enterprise sector, through providing supports for Irish SMEs and exporters to address their emissions, and by investing in carbon measurement and abatement technologies for manufacturing companies. • Roll out, through Science Foundation Ireland, a National Grand Challenges Programme of mission-orientated funding.” This seems new. Could become something useful. It then goes on to the usual EI and IDA based actions with nothing to indicate these will serve any wider audience than they do currently. |
124-135 | The focus on domestic dwellings seems to fly in the face of the policy of prioritising actions which give the best return on investment. Upgrading houses is much more expensive and less effective than the types of SME measures we have been working with, for example. Doesn’t that suggest our focus should be more on these areas? In the plan there is nothing much new to support improvement of commercial buildings. |
137 | “The existing Community Energy Grant (CEG) Scheme will remain open as a development call and available for those project co-ordinators who are not successful in registering as an OSS. The CEG Scheme will encourage the development of a pipeline of OSS service providers.” Sounds like CEG is being phased out in favour of one stop shops. |
145 | For there to be 845,000 EVs in place over the next 9 years, this means average EV sales of 93,800 per year, or almost 80% of all sales. YTD 2021 it is 8%. Doesn’t sound realistic. |
145 | Plan is to introduce 845,000 new EVs and at the same time reduce ICE kilometres by 10%. This sounds like a massive increase in car kilometres overall rather than the stated objective of an overall significant reduction. Maybe the EVs are expected to spend their time parked up? In 2018 Ireland had 2.1 million cars on the road. If this stays stable, and 845,000 of them are electric in 2030, that means 1.25 million ICE cars (a reduction of 40%). It could well be that most of these EVs will be hybrids, in which case this would be a very poor result. |
145 | Transport includes a further 0.9 Mt reduction from unidentified sources. About 15% of the overall planned transport improvement. Very weak given the EV targets for example. NB: This is over and above the unallocated 4 Mt of savings in the overall plan. |
151 | Not much on air transport other than continued international collaboration with EU and global agencies. While air transport isn’t included in the reporting figures, it should still be a major policy area for GHG reduction. |
188 | Ireland’s international action doesn’t seem to take account of just transition (i.e. rich countries such as Ireland should have a higher carbon reduction target that developing countries which are less able to invest.) |
The full 2021 Climate Action Plan can be found at: https://www.gov.ie/en/publication/6223e-climate-action-plan-2021/