Climate Change

FIE today called on the Government not to reallocate €5 million of EU funding away from Sustainable Energy. The proposed cut comes on top of a reallocation of €15 million last year. In view of rising oil and gas prices and all that implies for the Irish economy, it is incomprehensible for the Government to cut the nation's spend on sustainable energy initiatives.

Three FIE suggestions:

a) Low income Housing Programme.
The current programme for improving energy efficiency in the houses of the fuel poor will take 30 years at the current rate of investment. Fund this investment.

b) Grants for householders.
Unlike other EU countries, there are no grants for householders installing renewable energy facilities This is another obvious candidate.

c) Training, certification and quality control for renewable energy installers would address the lack of trained installers and the lack of confidence on the part of customers in new products and installers. Put the money here.

READ OUR PRESS RELEASE AND THE DOCUMENTATION OF THIS ASTONISHING CUT
FIE today called on the Government not to reallocate €5 million of EU funding away from Sustainable Energy. The proposed cut comes on top of a reallocation of €15 million last year. In view of rising oil and gas prices and all that implies for the Irish economy, it is incomprehensible for the Government to cut the nation's spend on sustainable energy initiatives.

Three FIE suggestions:

a) Low income Housing Programme.
The current programme for improving energy efficiency in the houses of the fuel poor will take 30 years at the current rate of investment. Fund this investment.

b) Grants for householders.
Unlike other EU countries, there are no grants for householders installing renewable energy facilities This is another obvious candidate.

c) Training, certification and quality control for renewable energy installers would address the lack of trained installers and the lack of confidence on the part of customers in new products and installers. Put the money here.

READ OUR PRESS RELEASE AND THE DOCUMENTATION OF THIS ASTONISHING CUT
FIE is supporting 18 environmental and development organisations who have issued a warning that debt relief, aid and trade will count for nothing unless global warming is addressed. 'It is no good to simply say that if the economic basis of African development can be sorted out by a responsibly rich world, the problem will be solved.'

'Up to 70% of Africans are immediately dependent on rain fed small scale agriculture. Luxury horticulture and extensive monocultures are not appropriate responses to the predicted decline of 10% in rainfall by 2050. Nor is the enormous EU supported growth in livestock production In Botswana. This puts great pressure on water supplies. A new test on all African aid must be the question, are you increasing or decreasing people's vulnerability to the climate?'

Read Our Press Release.

Read the Report.

FIE is supporting 18 environmental and development organisations who have issued a warning that debt relief, aid and trade will count for nothing unless global warming is addressed. 'It is no good to simply say that if the economic basis of African development can be sorted out by a responsibly rich world, the problem will be solved.'

'Up to 70% of Africans are immediately dependent on rain fed small scale agriculture. Luxury horticulture and extensive monocultures are not appropriate responses to the predicted decline of 10% in rainfall by 2050. Nor is the enormous EU supported growth in livestock production In Botswana. This puts great pressure on water supplies. A new test on all African aid must be the question, are you increasing or decreasing people's vulnerability to the climate?'

Read Our Press Release.

Read the Report.
Dear Minister,

We note you have called for tenders for 6 public service obligation internal aviation routes.

We are concerned that the operation of such tenders involves significant public expense with limited public benefit. In particular we are concerned at the significant negative environmental consequences of short-haul aviation, which has by far the highest impact on greenhouse gas emissions of all transport modes. We would ask you to consider the following facts:
Martin Cullen, TD,
Minister for Transport,
Department of Transport,
44 Kildare Street,
Dublin 2
17 March, 2005


RE: PSO subsidising short haul aviation

Dear Minister,

We note you have called for tenders for 6 public service obligation internal aviation routes.

We are concerned that the operation of such tenders involves significant public expense with limited public benefit. In particular we are concerned at the significant negative environmental consequences of short-haul aviation, which has by far the highest impact on greenhouse gas emissions of all transport modes. We would ask you to consider the following facts:

' Subsidy to these routes is now approaching the total subsidy to Bus Éireann
' Subsidy levels varied in 2003 from €53 per passenger each way for travel between Dublin and Galway to €290 per passenger each way for travel between Dublin and Knock.
' Average rail passenger subsidies are under €5 per passenger.
' This subsidy, by its nature is of greatest benefit to the more wealthy who are the most likely to avail of internal aviation, and therefore is socially regressive.
' The routes are competing directly with public transport. Four of the routes for which tenders are being sought compete directly with a direct rail service to Dublin. Derry has a direct bus service and an indirect rail service to Dublin and the area served by Carrickfinn Airport has a direct bus service to Dublin.
' CO2 emissions vary considerably but are usually taken as at least 6 times higher per kilometre for aviation as for rail.



We believe the following legal considerations are relevant:

1. Ireland is a signatory of the United Nations Framework Climate Change Convention and as such is committed under Article 4 to incorporate climate change considerations into its policies and to limit emissions.

2. Ireland is subject to the National Emissions Ceilings Directive and unless there is a change of policy will breach its emissions ceiling for NOx.

3. Council Regulation (EEC) No 2408/92 of 23 July 1992 on access for Community air carriers to intra-Community air routes requires that proposed PSOs fulfill a number of conditions. Article 4(1)b) provides that

" The adequacy of scheduled air services shall be assessed by the Member States having regard to:
"(i) the public interest;
"(ii) the possibility, in particular for island regions, of having recourse to other forms of transport and the ability of such forms to meet the transport needs under consideration;..."

4. Article 6 of the EC Treaty provides
"Environmental protection requirements must be integrated into the definition and implementation of the Community policies and activities referred to in Article 3, in particular with a view to promoting sustainable development."


In the light of the above facts and legal provisions, we submit that

1. The proposed subsidy to these short-haul aviation routes is not in the public interest in that
a. it leads to higher emissions of greenhouse gases
b. it leads to higher emissions of gases controlled under the National Emissions Ceilings Directive
c. it is a socially regressive transfer of wealth from the exchequer to the higher income users of the service
d. it contradicts stated public policy of favouring public transport

2. The proposed subsidy does not take account of the other forms of transport available between the areas served and Dublin which in the case of most of the proposed routes provide good transport links to Dublin.

3. The proposed subsidy is in conflict with Ireland's obligations under the National Emissions Ceilings Directive as it is part of a suite of policies which will lead to the Directive being breached.

4. The proposed subsidy is contrary to Ireland's obligations under Article 4 of the UNFCCC


5. The proposed subsidy is in breach of Article 6 of the EC Treaty. Although the regulation 2408/92 does not make reference to environmental protection requirement nor to sustainable development, it must now be interpreted subject to Article 6 of the Treaty. In failing to integrate environmental protection requirements in any fashion into the proposed subsidy and indeed, given the facts as set out above, in promoting the subsidy, the proposal is in breach of Article 6 of the Treaty.

Therefore, we call on you not to issue public service obligations on these routes, but to devote the funding instead to improving rail and bus links.

Sincerely yours,

David Healy



References:

DKM Economic Consultants Ltd, 2003, Review of Air Services Supported by the Essential Air Services Programme (Report to Department of Transport) http://www.transport.ie/upload/general/4803-0.pdf

Douthwaite, R., and Healy, D., 2004, Subsidies and Emissions of Greenhouse Gases from Fossil Fuels (Report to Comhar, National Sustainable Development Partnership) http://friendsoftheirishenvironment.org/pdf/subsidies.pdf
The environmental group Friends of the Irish Environment [FIE] have lodged formal complaints with the European Commission's Regional Directorate and the Environmental Directorate objecting to the use of Public Service Obligations to subsidise short distance flights from Dublin.
The group, which has also written to the Minister for Transport objecting to the recent announcement of tenders for the proposed PSO to fund these subsidies, says its complaint arises because of the significant negative environmental consequences of short-haul aviation.

The group suggest that emissions are at least 6 times higher per kilometre for aviation as for rail.

FIE claims that existing subsidies already range from €53 each way for Dublin-Galway to €290 per passenger each way for Knock-Dublin.

Four of the routes for which tenders are being sought compete directly with a direct rail service to Dublin. The group claims average rail passenger subsidies are under €5 per passenger.

FIE gives four grounds for its complaint:

' United Nations Framework Climate Change Convention commits Ireland under Article 4 to incorporate climate change considerations into its policies and to limit emissions

' Under the National Emissions Ceilings Directive, unless there is a change of policy Ireland will breach its emissions ceiling for NOx

' Council Regulation (EEC) No 2408/92 of 23 July 1992 on Air Transport Access refers specifically , in particular for island regions, of having recourse to other forms of transport and the ability of such forms to meet the transport needs under consideration"

' Article 6 of the EC Treaty requires that "Environmental protection requirements must be integrated into the definition and implementation of the Community policies and activities referred to in Article 3, in particular with a view to promoting sustainable development."

A spokesperson said that subsidies for internal short haul flights are a socially regressive transfer of wealth from the exchequer to the higher income users of the service as well as contradicting stated public policy of favoring public transport


Attribution: spokesman
Verification and comment: David Healy: 01-8324087 / 087 6178852

DKM Economic Consultants Ltd, 2003, Review of Air Services Supported by the Essential Air Services Programme (Report to Department of Transport) http://www.transport.ie/upload/general/4803-0.pdf

Douthwaite, R., and Healy, D., 2004, Subsidies and Emissions of Greenhouse Gases from Fossil Fuels (Report to Comhar, National Sustainable Development Partnership) http://friendsoftheirishenvironment.org/pdf/subsidies.pdf
The EPA has submitted the National Allocation Plan to the European Commission effectively unchanged from the version that was released for public consultation in March.

The plan means large windfall gains for major polluters such as the electricity and cement industries. It means the government will rely on using taxpayers money to purchase 3.7 million tonnes per year of carbon credits on the international market - the price of which is unknown but could easily reach 50 or 100 million/euro year.

To make it worse, the windfall electricity profits will derive from increased electricity prices to be paid by the consumer.

FIE believes the plan is in breach of EU rules because it seeks to protect the worst polluter: peat-fired electricity generation. 2 million tonnes per annum of credit are being allocated to peat-fired power plants. Therefore more than half of the government's planned purchase is attributable to the burning of peat. These plants already have a cross-subsidy of 58 million euro per year, levied on electricity bills. The plan should be based on the conversion of these plants to biomass such as willow.

The allocation to peat-fired plants is in breach of EU rules which require that the plan be based on the technological potential for emissions reduction.

FIE will be contacting the European Commission, who have the power to require changes in the plan.

Meanwhile Minister Cullen has expressed his view that the National Allocations Plan is enormously generous to big business in today's Irish Independent:
"But Martin Cullen does not believe any of the whingeing from companies about additional costs. In fact, he says the Irish system is enormously generous."

Attribution: Spokesperson
Contact: David Healy, 087 6178852
verdireATeircom.net

The EPA has submitted the National Allocation Plan to the European Commission effectively unchanged from the version that was released for public consultation in March.

The plan means large windfall gains for major polluters such as the electricity and cement industries. It means the government will rely on using taxpayers money to purchase 3.7 million tonnes per year of carbon credits on the international market - the price of which is unknown but could easily reach 50 or 100 million/euro year.

To make it worse, the windfall electricity profits will derive from increased electricity prices to be paid by the consumer.

FIE believes the plan is in breach of EU rules because it seeks to protect the worst polluter: peat-fired electricity generation. 2 million tonnes per annum of credit are being allocated to peat-fired power plants. Therefore more than half of the government's planned purchase is attributable to the burning of peat. These plants already have a cross-subsidy of 58 million euro per year, levied on electricity bills. The plan should be based on the conversion of these plants to biomass such as willow.

The allocation to peat-fired plants is in breach of EU rules which require that the plan be based on the technological potential for emissions reduction.

FIE will be contacting the European Commission, who have the power to require changes in the plan.

Meanwhile Minister Cullen has expressed his view that the National Allocations Plan is enormously generous to big business in today's Irish Independent:
"But Martin Cullen does not believe any of the whingeing from companies about additional costs. In fact, he says the Irish system is enormously generous."

Attribution: Spokesperson
Contact: David Healy, 087 6178852
verdireATeircom.net