The Irish Farmers' Association - IFA

Lobbying Organisation The Irish Farmers' Association - IFA

Date published 18 May, 2022

Relevant Matter Public policy or programme

Public Policy Area Environment

Period 1 Jan, 2022 to 30 Apr, 2022

Specific Details Climate Action - Carbon Budgets

Intended results To highlight that achieving the reduction target set for agriculture, of 22% to 30% by 2030, which represents an emissions reduction of between 5 to 7 million tonnes CO2 (Mt CO2), will be extremely challenging for the sector. To highlight that Irish farming is a world leader in grass-based food production and is a highly emissions-efficient, sustainable food production model. In dealing with the climate change challenge, it is imperative that Irish farmers' current sustainability credentials are fully acknowledged at the outset. To highlight that agricultural emissions, as a percentage of total emissions, have remained relatively static since 1990. While in the same period, emissions from transport have more than doubled from 9% to 19%. To highlight that since 1990 Irish farms combined have increased their output by approximately 40%. In spite of the increase in production total agricultural emissions by the sector have remained static with 19.5 million tonnes CO2e from the sector in 1990 and 21.4 million tonnes CO2e in 2020. Due to Ireland's existing emissions efficiencies in food production, the scale of the proposed reduction target of between 22% to 30% by 2030 for the sector, poses a significant challenge. To highlight the farming sectors' unique ability to remove carbon from the atmosphere by carbon sequestration through enhancing carbon sinks and reducing carbon losses as well as offset emissions in other sectors through on-farm renewables. To highlight that achieving emissions reductions will be extremely challenging for agriculture and is more complex than mitigation in other sectors. Agricultural mitigation involves the reduction of GHG emissions which are produced naturally as part of biological processes, thereby limiting the emission reduction options. To highlight that a reduction target of 22% for Agriculture is extremely challenging but based on potential mitigation measures outlined in the Climate Action Plan is achievable. To highlight to the Taoiseach and the Minister for Agriculture that the emphasis must be on reducing emissions, not on reducing output. To highlight that the global population is due to increase from 7.5bn today to an estimated 10bn in 2030. Global demand for meat and dairy products is increasing. Who will supply this food? There is a real risk that we will create a global food emergency trying to solve the climate emergency. To highlight that it would be a huge mistake to impose output restrictions of any kind on Irish farmers. To highlight that Farmers in Ireland produce some of the most carbon efficient beef and dairy in the world. We are more than willing to play our part in addressing the climate challenge, but using a ‘blunt instrument' to control output would be damaging for the future of Irish farming and rural Ireland. Farmers fully understand the need to reduce emissions, but we have a target for 2030, not 2023. We are confident that we can achieve our 2030 targets by using technology to reduce methane and Nitrous oxide output per animal. To acknowledge the Advantage Beef Programme launched by ABP is an attempt to promote younger age of slaughter for cattle sourced from suckler and dairy herds while also promoting lower levels of antibiotic usage. This programme is clearly seeking to react to the increased societal demands on climate action and antibiotic usage in food production. To highlight that the type of change at farm level to meet climate change goals will require direct financial supports from Government for cattle rearing and finishing farms. The following is the Executive Summary from the IFA Submission to the Public Consultation on Carbon Budgets - Irish agriculture is a world leader in sustainable food production and a highly emissions-efficient food production model. Maintaining a sustainable and competitive agriculture sector, while meeting the carbon reduction targets by 2030 must be priority when setting the carbon budget and emission ceiling for the sector. - The Climate Action and Low Carbon Development (Amendment) Act 2021 obliges the Minister and Government to ensure that the formation of the carbon budgets do not threaten food production and enable economic development to proceed in a sustainable manner. - Achieving the proposed carbon reduction targets will be extremely challenging for Agriculture and is more complex than mitigation in other sectors. The sector is less consolidated (approximately 140,000 farm families) and mitigation measures involve the reduction of emissions which are produced naturally as part of biological processes, thereby limiting the emission reduction options. - The difficulties in accurately measuring and accounting the reduction impact of the proposed measures for Agriculture in the Climate Action Plan 2021, within the EPA emissions inventories is recognised in the Climate Change Advisory Council (CCAC) Carbon Budget Technical report to “represent a very significant challenge”. - The report also acknowledges that the scope to mitigate emissions, particularly of methane emissions, is challenging over the first two carbon budget periods. - To provide a sufficient timeframe for adoption and in recognition of the economic and social importance of the sector, the lower carbon reduction target of 22% is needed. This would allow the sector to continue to improve efficiencies, adopt new technologies and innovative practices without needing to reduce output to meet climate objectives which could undermine competitiveness. - A late-action trajectory would provide time for developing technologies and innovations to be adopted, measured and verified to deliver additional migration potential. This would preserve economic productivity while significantly reducing methane emissions beyond 2030. - IFA welcomes recognition in the report that a requisite element in addressing climate change is to provide appropriate incentives for action. This very much echoes the findings of the Teagasc MACC report which identified incentives and training as key enablers to encourage and support farmers to change practices and uptake mitigation measures. - Farmers are crucial decision makers in the LULUCF process. Agriculture is unique in its ability to remove carbon from the atmosphere by carbon sequestration through enhancing carbon sinks. - The scale of the ambition in LULUCF is clearly evident when considering the rate of acceleration required to meet the afforestation targets. In 2021, the afforestation programme was approximately 2,000 hectares of which farmers planted just 380 hectares (19%). A quarter of 8,000 target in Climate Action Plan 2019 and 10% of 20,000-hectare programme referenced in the Carbon Budget Technical report. - Accelerating the afforestation programme will require the current forest programme and regulatory framework to be reformed. It will also be necessary to consider all suitable land types, including the significant area currently under-utilised (unenclosed land). - The recently published European Commission report on carbon farming shows that result-based carbon farming can contribute significantly to meeting carbon reduction targets. It has the potential to be win-win situation, increasing carbon sequestration and storage while offering new income opportunities for farmers. The success of a carbon farming scheme in Ireland and the scale of adoption will be dependent on the level of financial incentive introduced. - A major disadvantage for the sector is that there is no measurement, reporting and verification (MRV) for carbon sequestration in Irish grassland or peat soils. The establishment of National Agricultural Soil Carbon Observatory, which commenced monitoring in 2021 will take a number of years before evidence-based measurement, reporting and verification can be achieved. - ‘Net Net' accounting methodology is currently used in both Ireland and the EU in calculating emissions and removals for the LULUCF sector, this must be maintained in the accounting methodology in the carbon budgets. There is no current EU requirement to change the way that Ireland accounts for emissions and removals under LULUCF. - The single biggest barrier to meeting the climate action targets is the financial vulnerability of many farms. A recent KPMG report, commissioned by the Irish Farmers Journal, concluded an emission carbon reduction target of 30% would reduce agri-food economic output by €3.8 billion and reduce employment predominantly in rural areas by 56,400 jobs, possibly threatening the long-term competitiveness of the sector. - The single biggest barrier to meeting the climate action targets is the financial vulnerability of many farms. A recent KPMG report, commissioned by the Irish Farmers Journal, concluded an emission carbon reduction target of 30% would reduce agri-food economic output by €3.8 billion and reduce employment predominantly in rural areas by 56,400 jobs, possibly threatening the long-term competitiveness of the sector. - IFA supports Climate Change Advisory Council (CCAC) position as set out in carbon budget letter to Minister Ryan that provision should be made in the regulations for review and adjustment of carbon budgets and sectoral emissions ceilings if and when EU reporting requirements are revised based on best available science, particularly with regard to the impact of short-lived greenhouse gases such as methane. - The recent IPCC report acknowledges that new emission metric approaches such as Combined Global Temperature Change Potential (CGTP) and Global Warming Potential* (GWP*) give a better account for the different physical behaviours of short and long-lived gases. - Irish farmers are fully committed to playing their part in reducing emissions, however the carbon reduction target set for the sector must be achievable without undermining the economic viability of the family farm. With appropriate supports farmers can continue to innovate and adapt in Ireland's transition to a climate neutral economy. - Agriculture's unique potential to offset emissions and be a major part of the transition to a climate neutral economy through on-farm renewables, carbon farming and forest should be maximised to strengthen the sustainability credentials of Irish food production whilst reducing the impact on climate.

Name of person primarily responsible for lobbying on this activity Tim Cullinan IFA President, Brian Rushe IFA Deputy President, Damian McDonald IFA Director General, Tadhg Buckley IFA Director of Policy/Chief Economist, Elaine Farrell Director of Governance & Oireachtas Engagement, Geraldine O'Sullivan IFA Policy Executive,Brendan Golden IFA Livestock Chairman, Liam MacHale IFA European Director, Shane Whelan IFA Senior Policy Executive

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Meeting (2-5)

Email (6-10)

Social Media (2-5)

Virtual Meeting (1)

Submission (1)

Informal communication (2-5)

Phone call (2-5)

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Patrick Donohoe Special Adviser (Department of Agriculture, Food and the Marine)

Micheál Martin An Taoiseach (Department of the Taoiseach)

Charlie McConalogue Minister (Department of Agriculture, Food and the Marine)

Martin Browne TD (Dáil Éireann, the Oireachtas)

Jackie Cahill TD (Dáil Éireann, the Oireachtas)

Matt Carthy TD (Dáil Éireann, the Oireachtas)

Michael Collins TD (Dáil Éireann, the Oireachtas)

Michael Fitzmaurice TD (Dáil Éireann, the Oireachtas)

Joe Flaherty TD (Dáil Éireann, the Oireachtas)

Paul Kehoe TD (Dáil Éireann, the Oireachtas)

Brian Leddin TD (Dáil Éireann, the Oireachtas)

Michael Ring TD (Dáil Éireann, the Oireachtas)

Victor Boyhan Senator (Seanad)

Lynn Boylan Senator (Seanad)

Paul Daly Senator (Seanad)

Tim Lombard Senator (Seanad)

Denis O'Donovan Senator (Seanad)

Barry Andrews MEP (European Parliament)

Billy Kelleher MEP (European Parliament)

Chris MacManus MEP (European Parliament)

Ciarán Cuffe MEP (European Parliament)

Clare Daly MEP (European Parliament)

Colm Markey MEP (European Parliament)

Deirdre Clune MEP (European Parliament)

Frances Fitzgerald MEP (European Parliament)

Grace O'Sullivan MEP (European Parliament)

Luke Ming Flanagan MEP (European Parliament)

Maria Walsh MEP (European Parliament)

Mick Wallace MEP (European Parliament)

Seán Kelly MEP (European Parliament)

Richard Bruton TD (Dáil Éireann, the Oireachtas)

Réada Cronin TD (Dáil Éireann, the Oireachtas)

Cormac Devlin TD (Dáil Éireann, the Oireachtas)

Alan Farrell TD (Dáil Éireann, the Oireachtas)

Darren O'Rourke TD (Dáil Éireann, the Oireachtas)

Christopher O'Sullivan TD (Dáil Éireann, the Oireachtas)

Bríd Smith TD (Dáil Éireann, the Oireachtas)

Timmy Dooley Senator (Seanad)

Alice-Mary Higgins Senator (Seanad)

John McGahon Senator (Seanad)

Pauline O'Reilly Senator (Seanad)

Leo Varadkar An Tánaiste (Dáil Éireann, the Oireachtas)

Martin Heydon Minister of State (Department of Agriculture, Food and the Marine)

Philip O'Callaghan Special Adviser (Department of the Taoiseach)