Jesuit Centre raises concern over legality of government draft Climate Plan

Climate and Low Carbon Development Act

The Jesuit Centre for Faith and Justice has called upon the Government to adhere to the legislative requirements of the Climate and Low Carbon Development Act (2015) when formalising the National Mitigation Plan to reduce greenhouse gas emissions.

Catherine Devitt, Environmental Justice Officer with the Jesuit Centre for Faith and Justice said that “while the draft Mitigation Plan acknowledges the challenges that Ireland faces, it failed to outline in detail a specific mitigation framework for effective and just climate policy in Ireland. This goes against the explicit legislative requirements established by the Climate Act.”1,2

She acknowledges that there were some positive elements in the draft Plan but added, “Generally, it adopts a wait-and-see policy approach. The overall tone is cautious, almost defeatist, and climate action is framed as undesirable and costly. This is despite substantial evidence showing that the costs of inaction greatly outweigh the costs of action.”

Catherine Devitt noted that under the Climate Act, climate justice is one of the principles that Irish climate policy must give heed to.

“Our analysis of the draft Plan showed an absence of any reference to the profound local and global human and ecological costs of inaction, the costs of non-compliance with EU targets, the wider systemic risks of inaction, or how any of these costs will be managed”.3

Ms. Devitt says, “The non-negotiable nature of climate change and the imperative upon the State to protect its citizens from avertable harm requires an ambitious and equitable climate mitigation measures. We are urging the Government to bring forward a new Plan that presents a compelling vision for a decarbonised Ireland and that adopts a pragmatic and positive approach to climate action.”

The Environmental Protection Agency and the Climate Change Advisory Council (Ireland’s independent advisory body) have overtly stated that transformational change, long-term planning, and concrete policies are essential across all aspects of Irish society.4 In Laudato Si’, Pope Francis emphasised that reducing greenhouse gases requires responsibility, courage and honesty by countries that pollute the most (§ 169).5

The draft National Mitigation Plan, which recently closed for public consultation, is the first under Ireland’s Climate Action and Low Carbon Development Act (2015) and follows Ireland’s ratification of the Paris Agreement last year. The Climate Act requires that the Mitigation Plan must outline a specific policy roadmap that will enable Ireland to reach its short and long-term climate targets.

The joint submission, which includes 21 recommendations, is available online.6


1. Section 4(2) of the Climate Act (2015) stipulates that the National Mitigation Plan must specify: ‘the manner in which it is proposed to achieve the national transition objective’, and ‘specify the policy measures that, in the opinion of the Government, would be required in order to manage greenhouse gas emissions and the removal of greenhouse gas at a level that is appropriate for furthering the achievement of the national transition objective.’ The NMP must also ‘take into account any existing obligation of the State under the law of the European Union or any international agreement’, ‘specify the mitigation policy measures to be adopted by the Ministers of the Government…’, and include specific sectoral mitigation measures. The full Act is available at:
2. The JCFJ is a member of the Stop Climate Chaos coalition. Catherine Devitt, authored and coordinated a significant submission that they, and the Environmental Pillar group, submitted to government in response to the public consultation.
3. Analysis from the Institute of International and European Affairs (2016) found that the combined 2020 and 2030 non-compliance costs to the Irish taxpayer could exceed €6billion. This analysis is available at:
4. Comment from the EPA is available at: and comment from the Climate Change Advisory Council can be accessed at:
5. Encyclical Letter Laudato Si’ Of The Holy Father Francis On Care For Our Common Home (official English-language text of encyclical)”.
6. The joint Stop Climate Chaos and Environmental Pillar submission is available at: A summary document is available at: