Mr. John Muldowney:

I will take a step back from Dr. Hendrick's starting point. On the granting of access to LULUCF, the Council conclusions of 2014 set out the terms on which the non-ETS targets would be based. One of the principal targets on which this is built is paragraph 2.1.4 of the Council conclusions, which recognises the low mitigation potential of agriculture, together with the opportunities available in the land-use sector, in particular, in respect of afforestation. The analysis in the impact study we have seen examined the best means of allowing access to new flexibility in this area. Principally, our position is that this is not an offset but a means of accessing a new menu of options that was not available to us previously.

For a country like Ireland with a high cost of mitigating carbon, this sets out a new toolbox of options that helps to reduce that cost-effectiveness point for Ireland.

In terms of the LULUCF, afforestation is the key area where we will get most credits. The LULUCF proposal also acknowledges that those with credits in managed grasslands and managed croplands can also get access to those.

On the managed grassland and cropland, the principal point highlighted is that there must be new and additional activities in those areas. Therefore, it is not for the existing carbon pool which people identify with in grasslands, but for the new and additional work. Again we are working closely with Teagasc to see what new and additional opportunities are available. There are opportunities for better management of grasslands - better fertility of grasslands - to get a carbon credit for grassland.

The same is true of better management of arable silage; it is possible to build up that soil carbon pool. That is a new and additional activity, as with afforestation. It is new and additional, over and above the starting point. That is the principal direction in which we are trying to take this.

Every year the EPA reports to the UNFCCC on peatlands under the wetland category. It is then up to member states to elect to count for any potential credits. Again the main point is new and additional credits. We have not yet reached a stage where we can trust the science of our understanding to prove those new and additional credits. There are many ongoing research programmes involving the EPA, the Department of Agriculture, Food and the Marine, and the NPWS investigating opportunities in that regard. It can be looked at again in the future.

However, it is not totally excluded because peatland that is under agricultural management is covered by managed grassland or managed cropland. Approximately 300,000 ha of peatlands are managed grassland. If we can carry out activities on those that help to manage the water table in those managed grasslands that are peat-soil based, there are potential credits on those. So there is crossover in how one looks at it. The principal point to emphasise is that is it new and additional and therefore it is not an offset. It is not seen to balance against emissions that arise from fertiliser or livestock emissions. Livestock and fertiliser emissions have their own abatement options and we are also trying to address those.