Mr. David Healy:

The Environmental Pillar is made up of 26 national environmental NGOs advocating for sustainability and it is part of the Irish Environmental Network, IEN. This is basically our way of understanding what we are working towards. The economy is part of society and is dependent upon the environment. Climate change is one of our key areas of action. We have a climate and energy working group, and this presentation reflects that group's work.

Our recommendations fall under seven headings, the first of which is climate justice. I have included the following quote from the Tánaiste, Deputy Eamon Gilmore, at the recent climate justice event:

This is an injustice, pure and simple. ... It must be addressed – for reasons of morality and of self-interest. Because in our world today, the common interest is our self-interest.

We consider it essential that this approach and this understanding of climate as a justice issue is reflected in the law. One suggestion we have for the committee is that this would be based on Article 3.1 of the UN climate change convention, which states this should be "on the basis of equity and in accordance with their common but differentiated responsibilities and respective capabilities" of the member parties to the convention.

The next issue is targets. As the committee knows, we are looking, in particular, for a 2050 target but also for interim targets for the period up to 2050. The two core reasons for this are first, to drive Government Departments and agencies to undertake the challenge of transition given that in the past ten years we have seen insufficient buy-in from a number of elements of the State, and second, to give confidence for long-term investment decisions towards the low carbon, climate resilient, environmentally sustainable economy which is the objective of the Bill.

It is the governance aspects of the Bill that will make it work. We believe we should look at this as if it was 2050 and we were looking back at what we are doing today and taking a long-term view asking which is more important, the climate crisis or the fiscal crisis. We believe the Fiscal Responsibility Act 2012 is a very good model for strong climate governance. The Act states in its provision with regard to targets: “The Government shall endeavour to ensure that [the targets] are complied with”. We would like to see a similar obligation in this Bill. In addition, the Irish Fiscal Advisory Council is a good model for what we would like to see as a climate advisory council. The term "expert advisory body" often disappears and people ask "What is that?", whereas the Irish Fiscal Advisory Council is explicitly stated in the legislation as being independent in regard to the performance of its functions. The relevant section of the Act continues in clear detail to outline the obligations of the council and how it monitors and advises.

Public scrutiny is an essential part of that process because it creates accountability, builds credibility, creates a better understanding, which is a key aspect of climate change policy, and leads to better compliance and participation. We refer the committee back to the Aarhus Convention as the legal basis for this level of engagement. One point in particular is that in head 11 of this Bill, the definition of public bodies is related back to the Freedom of Information Act whereas we would rather see it relate back to the definition used for access to information on the environment regulations, which is the Aarhus understanding of public bodies and is a good bit wider.

We advocate that there should be a climate fund, which would reflect the fact climate justice has two parts, first, to reduce emissions, which is what most of the discussion here has been about and, second, to help mitigation and adaptation in developing countries in particular. The Scottish example of a climate fund is one which we advocate is followed. I know Mr. Stewart Stevenson, MSP, is coming to the committee later and he might provide more details on that. We see it as important that the climate fund is funded from the carbon tax and from the auctioning of ECX emissions and other climate-related financial instruments.

A section in the heads of the Bill lists considerations to be taken into account. We believe several areas are missing, the most striking gap being public health. The public health benefits of a number of climate-related measures are striking and much bigger in their impact than the climate impact. Clean air, increased activity and healthier diets all have a big impact on public health and, we believe, should be linked back to that section of the heads. Sustainability and environmental protection need to be explicitly mentioned, particularly biodiversity. There is a risk that some measures to take action on the climate can have a negative impact on biodiversity while others will have a positive, synergistic impact. Global impacts and food security are also key.

Black carbon is a climate pollutant which is not a gas and, therefore, is not covered by the current definitions in the heads. Ireland has recently joined the Climate and Clean Air Coalition and we are committed to taking action on black carbon. As Deputy Catherine Murphy's Bill intended, we need to provide that black carbon can be included within the scope of this Bill as policies develop at an international level.

We need specifically to address the potential for carbon sequestration because the potential for this is substantial in Ireland. If we can restore boglands, which at the moment are losing 4 million to 5 million tonnes of carbon a year, we can hold those stores. Forestry has also been discussed in this regard but soil carbon sequestration does not get enough attention, although it is an essential part of climate protection. The tendency has been to see it as a way of offsetting fossil fuel use, which is not correct. We need to deal with fossil fuel use but we also need to maximise the storage and sequestration of carbon.