1/29/24, 2:03 PM Climate Action Plan 2024 Proposed by Irish Government - Lexology

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Climate Action Plan 2024 Proposed by Irish Government

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Mason Hayes & Curran LLP

European Union, Ireland January 15 2024

The Climate Action Plan (CAP) is the Irish Government’s roadmap to delivering on its climate targets. It was
first published in 2019 and was later updated in 2021 and 2023. Under the Paris Agreement and the European
Green Deal, Ireland is committed to reducing greenhouse gas emissions (GHG) by 51% against 2018 levels by
2030 and to becoming carbon neutral by 2050. The aim of these commitments is to try collectively with other
nations to limit global warming to 1.5°C. While the Government’s proposed CAP 2024 is yet to undergo
environmental assessment and public consultation, we review its targets and policies for renewable energy.
Where we are now
The Environmental Protection Agency (EPA) of Ireland has reported that electricity generation accounted for
14.4% of Ireland’s total GHG emissions in 2022. During the whole of 2022, GHG emissions from electricity
generation fell by 1.9% due to an increase in renewable electricity generation coupled with a reduction in the use
of fossil fuels. However, to stay within the first carbon budget of 40 MtCO2eq assigned to the electricity sector
for the period 2021-2025, the electricity sector requires a decarbonisation rate of 17.3% per annum in the period
2023-2025. For context, the average decarbonisation rate between 2018 and 2022 was 1.4% per annum.
The EPA’s projections indicate that if all the measures in CAP 2023 and the ‘yet unallocated emissions savings’
(savings that are expected to be achieved through future advancements in technology and other areas) are
accounted for, the projected total emissions reduction for all sectors by 2030 will be 42%. This represents a 9
percentage point shortfall of the EU’s 2030 reduction target of 51% against 2018 levels. This is a significant
residual gap that CAP 2024 aims to close by setting out further policies, measures, and actions in addition to
those set out in earlier editions of the CAP. These additional measures are outlined below. A radical reduction of
emissions in the electricity sector, through the adoption of a renewables-led system, remains at the core of CAP
2024.
Where we are going
The key targets from CAP 2023 with regard to renewable energy are retained in CAP 2024. They are:

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1/29/24, 2:03 PM Climate Action Plan 2024 Proposed by Irish Government - Lexology

New policies, measures and actions

Some of the new policies, measures and actions included in CAP 2024 to achieve these targets include:
Accelerate renewable energy generation
To reach 80% of electricity demand from renewable sources by 2030, the Government is aiming to accelerate the
delivery of utility-scale onshore wind, offshore wind, and solar projects through a competitive framework. This
will involve updating existing policies and guidelines to streamline the consenting process. It is intended that the
following documents which were intended to be published under CAP 2023 save for the newly proposed Solar
Energy Development Guidelines will be revised, updated, and published during the lifetime of CAP 2024:
Update the revision of the National Planning Framework,
Publish a new Electricity Generation Grid Connection Policy,
Publish the Draft Renewable Electricity Spatial Policy Framework White Paper,
Publish the revised methodology for Local Authorities Renewable Energy Strategies
Publish the Draft Revised Wind Energy Development Guidelines
Commence drafting Solar Energy Development Guidelines
Adopt the Electricity Storage Policy Framework
Following finalisation of a Regional Roadmap, regional assemblies will publish and implement Regional
Renewable Electricity Strategies (RRES). This will enable a unified methodology for national and regional
spatial and capacity targets, and identify areas suitable for renewable electricity deployment at regional and
county levels that can inform the statutory planning process, and
Following adoption of the RRES, local authorities will include a statement within their next Local
Authority Climate Action Plans which identifies the methods or processes that will be used to implement
the required policy supports to achieve renewable electricity targets.
2030+ Offshore Renewable Energy Roadmap
The publication of a ‘2030+ Offshore Renewable Energy Roadmap’ is planned for Q2 2024. The purpose of the
roadmap will be to determine pathways to deploy offshore/ocean technology. This will involve producing
technology scenarios, conducting stakeholder consultation, and identifying enabling policies and the appropriate
regulatory framework.
Offshore Renewable Energy Innovation Park
By Q4 2024, the Government aims to finalise and publish a ‘Designated Maritime Area Plan’ for the
development of an offshore renewable energy innovation park. This will involve exploring options for grid
connection, options for routes to access and operating model, and publishing a report on the critical path
deliverables achieved to facilitate the ‘Routes to Access Phase’ of the proposed innovation park.

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1/29/24, 2:03 PM Climate Action Plan 2024 Proposed by Irish Government - Lexology

Hydrogen ambition
The Government intends to address unallocated GHG emissions savings by increasing hydrogen ambition to
achieve hydrogen uptake in line with the ambition outlined in the National Hydrogen Strategy. This will be
primarily through scaling electrolyser capacity. The Government is also aiming to support green hydrogen
production through surplus generation from 2GW of offshore wind energy. This is to provide greater certainty for
investors and to create the production scales needed to enable greater infrastructure deployment.
Low carbon flexibility opportunities
To further address unallocated GHG emissions savings, the Government intends to build out low carbon
flexibility opportunities such as long duration energy storage. The deployment of carbon capture, utilisation, and
storage (CCUS) technology was not integrated in previous editions of the CAP. By incorporating CCUS into
CAP 2024, it is hoped to address a portion of unallocated savings in Ireland between 2026-2030 with regard to
electricity generation. It is expected that this technology will play a significant role in future decarbonisation of
the energy sector. To achieve this, the Government intends to incentivise and enable large energy users to
participate in flexible demand initiatives. This approach is designed to enable low / zero carbon demand growth,
and to create a route to market for medium and long duration storage facilities which can provide flexible
demand.
Community Benefit Fund
All new or repowered renewable electricity generation projects will be required to implement a Community
Benefit Fund equivalent to the RESS requirements of €2/MWh. The establishment of community benefit funds
for renewable energy projects is considered to improve public acceptance of projects at a local level. This is
fundamental to increasing the level of consents being granted for renewable energy projects.
Comment
Delivery and integration of onshore and offshore wind and solar PV continues to be recognised in the CAP as the
best-performing mitigation measure to deliver the required emissions abatement at scale and at speed to achieve
Ireland’s GHG emission reduction targets. This is because no other supply-side measure comes close to the
emissions abatement achieved by the early and rapid deployment of wind and solar capacity. It is estimated that
an eight-times increase of renewable energy deployment to 2.3GW annually is needed between 2024 and 2030,
together with the delivery of at least 2GW of new flexible gas-fired generation.
CAP 2024 seeks to achieve these targets by trying to build on measures in earlier editions of the CAP, such as the
expected enactment of the Planning and Development Bill 2023, aimed at streamlining the consenting process.
CAP 2024 will be subject to public consultation and environmental assessment before being finalised and
adopted by the Government. It is possible therefore that there will be further changes to the plan and to the
timeline for its adoption.

Mason Hayes & Curran LLP - Jay Sattin, Deirdre Nagle and Eoin Cassidy

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