Northern Ireland is committed to Net Zero under the Climate Change Act (NI) 2022 (see recent insight). This involves setting 2030 and 2040 emissions reduction targets and five yearly ‘carbon budgets’ that are legally binding. 

DAERA must prepare regulations on carbon budgets and interim targets, guided by advice from the UK’s independent Climate Change Committee (CCC). The latest consultation is an opportunity for stakeholders to have their say on both the targets/budgets and the CCC’s Advice Report, and is open until 1 October 2023.  

Emissions targets and carbon budgets

DAERA must decide whether the 2030 and 2040 targets are consistent with meeting the net-zero 2050 targets. 

The CCC recommended that all NI departments ensure GHG emissions in NI are:

  • a 48% reduction from the 1990 baseline by 2030; and 
  • a 77% reduction from the 1990 baseline by 2040.

The following average annual reductions compared to the baseline are also recommended:

  • Carbon budget 1 (2023-2027) – 33% reduction
  • Carbon budget 2 (2028-2032) – 48% reduction
  • Carbon budget 3 (2033-2037) – 62% reduction 

The above budgets must be set by DAERA by December 2023 however all NI departments are required to ensure the carbon budgets are met. Carbon budgets set legally binding limits on the amount of GHG that can be emitted in a 5 year period. They will be delivered through the development of climate action plans and another consultation will follow on the draft Climate Action Plan 2023-2027. 

The NI Climate Commissioner and Just Transition Commission should be set up in time to prepare the fourth carbon budget in 2025.

This consultation asks whether responders agree on DAERA following the above targets or reasons for suggested alternatives are requested.  

The emissions reduction targets are hugely challenging and require a level of co-ordination and co-operation between NI government departments that has perhaps eluded them in the past. Of course the ongoing political instability in the region presents its own challenges. What this part of the consultation does not cover, however, is the means by which these reduction targets will be met. This is addressed in the second part of the document. 

CCC Advice Report: The Path to a Net Zero NI

NI Departments have set out their views alongside CCC advice on how to facilitate climate action. Importantly, the CCC advice recognises that the pace of decarbonisation in NI must increase rapidly so two options have been proposed for NI to pursue in order to reach Net Zero by 2050. 

“Updated Balance Pathway” –this proposes an 83% reduction in 1990 baseline emissions by 2050 involving most sectors decarbonising completely. For example, decarbonising electricity, zero emissions for new car sales, reducing livestock, increasing peatland restoration and all new heating appliances to be zero-carbon by 2033.

“Stretch Ambition” – in order to close the emissions gap to 93% by 2050, these proposals increase the amount of carbon sequestered in land and provide engineered GHG removals by afforestation and CO2 capture from solid biomass and anaerobic digestion of wastes. Notably, the report suggests that NI is not geologically suitable for CO2 storage sites – clearly this is a key area of response for those who disagree.

However, the CCC report concludes that even if NI follows the pathways it will not be enough to reach the 2050 target. The CCC report therefore recommends that a combination of speculative options should also be pursued. Direct air capture of CO2  with carbon capture and storage (outside NI) is the preferred option over the agricultural options since reducing livestock numbers in half would have more economic and social implications. Other options include enhanced cropland weathering and the addition of biochar to agricultural land. 

This section of the consultation lays out the stark and immediate challenge that faces NI in its journey to net zero with even the most ambitious option only reaching 93% of the target by 2050. There is the potential for more innovative thinking around how the targets can be met, particularly within the agricultural sector. It is also notable that the CCC report seems to reject outright the possibility of carbon storage within Northern Ireland, and whether this might be feasible or technologies could be developed to make it feasible. 

Sector Contributions for Net Zero 

The remainder of the consultation relates to CCC’s advice on policy changes by sector as summarised below.

Agriculture – assumes a significant reduction in livestock numbers and an associated transition to bioenergy cropping and increased forestry.

Land use and land use change – for example increasing the rate of afforestation, peatland restoration, carbon removal and storage.

Buildings Sector – to develop a plan to improve energy efficiency and reduce reliance on fossil fuels in homes including construction and retrofitting, with the NICS phasing out fossil fuel boilers. 

Transport – a new regional transport strategy is expected to be published this year and a suite of transport plans to be developed in conjunction with the new LDPs. The new hierarchy aims to substitute trips, shift modes and switch fuels.

Energy – the Energy Strategy increased the amount of electricity consumption from renewables sources to 80% by 2030. Electrification of other sectors will lead to increased electricity demand  - a key challenge to overcome.

Business and Industrial – increasing the amount of renewable energy generation, energy efficiency of buildings, and doubling the size of the low carbon economy by 2030 with hydrogen and carbon capture to be key drivers.

Waste – to reduce waste sent to landfill sites and reform recycling. 

Fisheries – plans to develop zero-carbon shipping clusters by 2030.

Feedback provided in relation to the above sectors will inform specific policies and proposals for inclusion in the Climate Action Plan consultation. There is scope within the consultation to comment on and potentially influence the proposals within each of the above sectors. Given that the carbon budget reductions cover a wide array of sectors and activities in Northern Ireland over the remainder of this decade and beyond, the importance of this consultation should not be underestimated. 

Next steps

This legal insight briefly summarises the headline points. We recommend that all stakeholders review the consultation and CCC report in detail and respond before the deadline.

The consultation will run until 1 October 2023. These targets and carbon budgets must then be set through regulation and agreed by the NI Executive before being laid before the NI Assembly for approval (once it is back up and running).

It is also anticipated that the draft Climate Action Plan will be issued for consultation as soon as possible after Executive consideration and so the views of the sector proposals will help inform this.

There are also public consultations taking place on the following dates:

  • Derry/Londonderry - 31 August 2023, 2pm - 4.30pm

  • Belfast - 05 September 2023, 2pm - 4.30pm

  • Online - 07 September 2023, 7pm - 8.30pm

Response forms can be emailed to DAERA at or via the online form. Please click here for a copy of the consultation.  

TLT’s Belfast-based Planning, Environment & Clean Energy team advises on all aspects of planning and environmental law in Northern Ireland and are qualified in Northern Ireland, England & Wales and the Republic of Ireland. For more information, please contact Andrew Ryan or Sarah Mulholland.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at July 2023. Specific advice should be sought for specific cases. For more information see our terms & conditions.


Written by

Sarah Mulholland

Sarah Mulholland

Date published

05 July 2023

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