Dr. Ciara Brennan:

I am happy to take this one. We have had some good engagement with the Department. Officials have been willing to meet us as stakeholders in the process. We met them yesterday and they gave us an update on the timeline. They told us that there will be more data. There was a lot of missing data the last time, which made it quite difficult to assess what the gap would be or where the gaps would lie. The Commission also highlighted that. It critiqued the absence of scenarios, assumptions and pathway data. It was difficult for anyone to tell what the plan was, within the plan. Officials have indicated that some of those gaps will be filled in the final document, such as with additional measures, WAM, and without existing measures, WEM. Those WEM and WAM issues will be more thoroughly exposed in the updated or final version. The Department indicated, however, that there will still be a gap. That will not be filled by the production of a good plan. It has to be filled by the policy cycle and by implementing all the aspects of the plan and the additional measures that are required. There will definitely be a gap. The benefit of the NECP process is that it is designed to show transparently where we are, what progress we have made and in which areas we need to make more progress.

If we do not meet the requirements there are a number of potential consequences. There are the consequences of having a weak NECP both substantively and procedurally. There are issues. We have legal obligations we are simply not meeting at this stage so we have potential infraction fines. It also opens up the risk of litigation because, as stakeholders, for example, we see that the deficits in public participation are in breach of the Aarhus Convention and a whole array of other legal obligations we have internationally and domestically. The consequences could range from EU imposed infraction fines, which we may see - we know many member states have struggled with the NECP and long-term strategy processes; that is certainly one issue - and potential litigation by citizens or organisations.