Technical analysis of the Commission’s proposal is on-going and will not be completed for some time. The Impact Assessment, published in tandem with the Commission Communication on a policy framework for climate and energy in the period 2020 to 2030, provides indications of where the burden would fall in terms of greenhouse gas emission reductions in the event that the proposal is accepted as presented and in its entirety. The technical work by my Department is focussed on making an assessment of both the robustness and affordability of the proposal. A definitive comparative analysis would require a breakdown of the results of the Commission’s analysis at a level that is currently not available to Member States.
Pending further information from the Commission on its impact assessment, the initial analysis by my Department is being carried out, using assumptions about sectoral impacts of the proposal. This ongoing work points to significantly higher levels of marginal abatement cost and a larger impact on energy costs as a percentage of GDP for Ireland than estimated by the Commission. These are matters of serious concern for Ireland in terms of the overall fairness of the proposed framework, including the economic impact.
It is important to stress that this initial analysis is based on a number of assumptions and that a further round of analysis, based on a more detailed breakdown of the Commission’s impact assessment, may differ in nature and degree. My Department has initiated engagement with the Commission regarding the technical analysis underpinning its Impact Assessment, to gain a clearer understanding of the analysis and further refine our own assessment.