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Report Title
2014 Energy Green Paper
Response Submission
Tipperary Community Stakeholders in Energy
Prepared by the following Tipperary Community Stakeholders
Templederry Community Windfarm
Drombane Upperchurch Energy Team Cloughjordan EcoVillage
Birdhill Tidy Towns/ Energy Team Lorrha and Rathcabbin Energy Team Kilcommon/Rearcross Energy Team
Gurteen Agricultural College
And Supported by
The Tipperary Energy Agency Tipperary County Council
North Tipperary LEADER Partnership Limerick Institute of Technology, Tipperary
Green Paper Submission Page 2 of 20
Contents
EXECUTIVE SUMMARY ........................................................................................................................ 4
1 INTRODUCTION ............................................................................................................................ 5 1.1 PARTICIPATING STAKEHOLDERS ............................................................................................... 5
2 RECOMMENDATIONS .................................................................................................................. 8 2.1 ENERGY PLANNING AND ENGAGING CITIZENS ............................................................................ 8 2.2 LOCAL AND COMMUNITY DEVELOPMENT .................................................................................... 9 2.3 SUPPORTING SUSTAINABLE ENERGY ...................................................................................... 11 2.4 OWNERSHIP OF DISTRIBUTED SUSTAINABLE ENERGY ASSETS ................................................. 12 2.5 EDUCATION ........................................................................................................................... 13 2.6 PENALTIES AND INCENTIVES ................................................................................................... 14 2.7 REGULATION AND ADMINISTRATION: ....................................................................................... 18 2.8 MONEYPOINT ......................................................................................................................... 19
3 CONCLUSION ............................................................................................................................. 20
4 BIBLIOGRAPHY .......................................................................................................................... 20 The Tipperary Energy Agency’s support for this submission was co-funded as part of the Academy of Champions of Europe (ACE)
1 Project which is funded by INTERREG North-
West Europe (NWE). This is a programme of the European Union to promote the economic, environmental, social and territorial future of the North-West Europe area. To this end, the sole responsibility for the content of this report lies with the authors and contributors. It does not necessarily reflect the opinion of the European Union.
1 www.aceforenergy.eu
Green Paper Submission Page 3 of 20
List of Abbreviations and Acronyms
ACE - Academy of Champions of Europe
BGE - Bord Gais Energy
CER - Commissioner for Energy Regulation
DCENR - Department of Communications, Energy and Natural Resources
DECLG - Department of Environment, Community and Local Government
DH - District Heating
DUET - Drombane Upperchurch Energy Team
EE - Energy Efficiency
EIB - European Investment Bank
EPA - Environmental Protection Agency
EV - Electric Vehicle/s
HECHP - High Efficiency Combined Heat and Power
IEA - International Energy Agency
LA - Local Authorities
LARES - Local Authority Renewable Energy Strategy
LIT - Limerick Institute of Technology
NEEAP – National Energy Efficiency Action Plan
NESC - National Economic and Social Council
NREAP - National Renewable Energy Efficiency Action Plan
NSAI - National Standards Authority of Ireland
NTLP - North Tipperary Leader Partnership
PS - Public Sector
PSO - Public Service Obligation
REFIT - Renewable Energy Feed-In Tariff
RES - Renewable Energy Sources
RHI - Renewable Heat Incentive
SEAI - Sustainable Energy Authority of Ireland
SEM - Single Electricity Market
TEA - Tipperary Energy Agency
Green Paper Submission Page 4 of 20
Executive Summary
County Tipperary is recognised as one of the most active counties in Ireland from a sustain-able energy perspective. There are a number of leading community groups, state and non-state organisations engaging in the improvement in the sustainability of energy use. Repre-sentatives from these groups participated in a full day workshop organised by Tipperary Energy Agency (TEA) in Limerick Institute of Technology (LIT), Tipperary on the 3
rd July
2014. These community groups sought to make a joint submission to the Department of Communications, Energy and Natural Resources (DCENR) in a clear and concise manner as possible. The submission is primarily concerned with the views and suggestions of community stake-holders. In this regard, it is considered that the delivery of a National Energy Policy is signifi-cantly dependent on the commitment of local groups and community led initiatives. A summary of the recommendations as follows: o Establish a National Plan for 2050 through a wide consultation process that engages
society, elected members (committee consultations, Seanad and Dáil debates), the me-dia and bridging organisations. Once the main elements of the plan are accepted, this should be supported through local targets, funding, marketing, and the required imple-mentation plans by the relevant state agencies. This Plan will then guide the National Energy Efficiency Action Plan (NEEAP) and National Renewable Energy Efficiency Ac-tion Plan (NREAP) as the 1-5 year implementation of the vision. The Plan should also have a full map of departmental and local targets and enabling supports to achieve the plan. This approach should be in line with the German “Energie Wende”
2 or the Danish
2050 plan3.
o Support for local technical (e.g. local Energy Agencies) and animation intermediary or-
ganisations (e.g. community development bodies) to deliver the Plan, (Berkes, 2009). This could include specific number of communities engaged, specific number of feasibil-ity studies completed, support applied for, delivery targets etc. It should include a na-tional co-ordinating body (e.g. Sustainable Energy Authority of Ireland (SEAI)) that in-cludes co-ordination, capacity building, and quality control.
o Incentivise the switch to a low carbon economy. This could be achieved through appro-
priate tax and subsidy measures that reward consumers that are proactive in reducing consumption of fossil fuel based energy in favour of renewable energy sources. This ap-proach has been successful in Austria and Denmark to achieve a high uptake of bio-mass, heat pump heating systems, photovoltaics system and wind energy.
2 Energiewende (Meaning: Energy Transition): The Energy transition (German: Energiewende) is the shift to sustainable econ-
omies by means of renewable energy, energy efficiency and sustainable development. The final goal is the abolishment of coal and other non-renewable energy sources. (www.energytransition.de)
3 http://www.kebmin.dk/sites/kebmin.dk/files/news/from-coal-oil-and-gas-to-green-
energy/Energy%20Strategy%202050%20web.pdf
Green Paper Submission Page 5 of 20
1 Introduction
The community stakeholders (listed on the title page) seek to aid DCENR in developing a long term robust energy plan for Ireland. The group feels that the imperatives of climate change, need for economic gain and competitiveness, energy security and peak oil are all leading to the conclusion that Ireland needs to substantially transform it’s energy system to 100% renewable energy by 2050 (or to as near as possible). The group participated in a full day workshop organised by TEA in LIT, Tipperary on the 3
rd
July 2014 to consider these main themes and collaboratively prepared this submission based on their respective expertise.
1.1 Participating Stakeholders
Tipperary Energy Agency: Tipperary Energy Agency was established in 1998 by the Tipperary Local Au-thorities and the then Tipperary Institute (now LIT Thurles) as an independent not-for-profit limited com-pany. The agency’s technical experts enable local authorities, communities and businesses to deliver renewable energy projects and become more energy efficient. The not-for-profit model enables the agency to provide cost effective professional services at a local and national level. Services include strategic energy management advice, energy project manage-ment and energy audits. The agency’s work includes major housing retrofit schemes, pioneering community wind farm developments and numerous biomass pro-jects. In addition, the agency has successfully com-pleted 25 European demonstration projects focussing on areas such as Renewable Energy, Sustainable Transport, Building Energy Performance and Bioenergy.
Templederry Community Wind farm: Ireland’s first community wind farm. The public consultation led by Prof. Tom Collins in 1999, established wind energy as a basis for development of the community. The development company estab-lished the wind farm after over-coming many development barri-ers. Several further activities are underway including wood energy, another wind energy project and a fully licensed energy supplier. The Windfarm is owned by 27 individu-als in the parish of Templederry and has a 7% share for a commu-nity fund. This community fund will
seek to support the wider community sustainable energy from when debt service reserves are established. Over the initial 20 year lifetime this will generate up to €15M Euro to the
Figure 1 - Paul Kenny CEO receiving the
Green Leader Award 2013
Figure 2 - Minister Rabbitte Opening Templederry Wind Farm
September '13
Green Paper Submission Page 6 of 20
local economy excluding debt/ turbine payments. This is the equivalent to 20-25 full time equivalent jobs for 20 years in a small upland parish with little other opportunities. The sig-nificance of the socioeconomic value of this type of development should not be overlooked. Tipperary Energy Communities of Drom-bane Upperchurch Energy Team / Birdhill Tidy Towns/ Energy Team / Kilcom-mon/Rearcross Energy Team / Lorrha and Rathcabbin Energy Team: are fully estab-lished energy teams working on community energy retrofit as a tool to stimulate rural economic regeneration in their parishes. Having developed from a single parish pro-ject in 2012, significant potential exists to animate other areas in the county. Local wood energy supply chains are a further activity that is being explored once these significant energy efficiency activities are completed. Drombane Upperchurch Energy Team (DUET) was awarded the “Best Commu-nity Energy Project” at the 2013 Local Authority Members Association (LAMA) awards.
Cloughjordan EcoVillage: The Cloughjor-dan EcoVillage is widely recognised as a leading development in sustainability. Cloughjordan EcoVillage has the largest cluster of A and B rated houses in Ireland. It’s Solar/ Biomass District heating system is leading best practice. Several spin off employment opportunities have been cre-ated including a green enterprise centre, educational courses, eco-finance devel-opment, food production and sustainable agricultural courses. Several thousand people have visited Cloughjordan EcoVil-lage to learn about it. It has received local, national and global awards for leadership,
community development and sustainability. Gurteen Agricultural College: Gurteen Agri-cultural College educates 400 full time and part time students each year. With the help of the Sustainable Energy for the Rural Vil-lage Environment (SERVE) project, SEAI and leadership from its supporters, Gurteen achieved an unparalleled transformation from peat and imported electricity to self-grown willow for heating and a 50KW wind turbine to power the facility.
Figure 4 - DUET LAMA Award
Figure 3 - Cloughjordan EcoVillage receiving Interna-
tional Award for liveable Communities 2013
Figure 5 - Harvesting Willow in Gurteen College
Green Paper Submission Page 7 of 20
Limerick Institute of Technology, Tipperary: Formerly the Tipperary Institute/ Tipperary Rural Business Development Institute. It has been a leader of sustainable energy education since its establishment in 1998. LIT Tipperary developed the first renewable energy course in 2001 and has since led many EU projects, educational courses, and development initiatives to promote sustainability and sustainable energy. LIT Tipperary co-ordinated the Build-Up Skills Road Map
4 for construction skills in addition to establishing an exchange programme
that has sent over 500 Irish building professionals and trades to German craft skills devel-opment centres. Tipperary County Council: Tipperary Local authorities (LA) have been a leading local author-ity in energy efficiency and renewable energy in their own energy use and in leading the county as a whole. Some achievements:
29% energy use reduction by North Tipperary Co-Co based on the SEAI’s Monitoring and Reporting figures for 2011.
Participation in the €10M EU concerto SERVE project (supported the installation of 1000m
2 solar thermal, 2.5MW large biomass, 2.6MW small biomass and the deep
retrofit of 400 buildings).
Tipperary Co-Co has switched 90% of heat use from fossil fuels to renewable or High Efficiency Combined Heat and Power (HECHP), retrofitted almost all buildings, established a detailed energy management programme.
South Tipperary County Council prepared a Renewable Energy Strategy for the County in 2013 in line with SEAI guidelines and with innovative elected member con-sultation and input.
The Council works in close consultation with the TEA on a large number of Renewa-ble Energy (RE) projects.
North Tipperary LEADER Partnership: NTLP is the local development agency for the North Tipperary area. The company has provided animation support and fund-ing to enable Tipperary to become a leader in community energy. NTLP fund-ed the initial economic development plan in Templederry and several other phases to realise the first community wind farm in Ireland. They have further supported the development of Tipperary Energy Com-munities, an umbrella body overseeing community retrofit projects in Drombane Upperchurch, and more recently in 3 oth-er communities Birdhill, Lor-rha/Rathcabbin and Kilcommon/Rearcross. An additional 8 communities have expressed an interest in participating in 2015.
4 http://www.ireland.buildupskills.eu/en/eu-activity/build-skills-ireland-national-roadmap-energy-training-
construction
Figure 6 - NTLP supporting Templederry Wind farm
Green Paper Submission Page 8 of 20
2 Recommendations
The key recommendations of the group are set out below. These have been developed with a view to ensuring the sustainable development of the renewable energy resources of the country.
2.1 Energy Planning and Engaging Citizens
Opportunity: Plan led leadership with widespread social and societal support: The first and arguably the main question of the Green Paper is how to engage society in a meaningful way, on how short term energy related decisions affect the long term socio-economic well-being of the country. The National Economic and Social Council (NESC) report (June 2014) on building social acceptance of renewable energy establishes a set of recommendations that are in line with the recommendations of the group. The report establishes a case for a plan-led approach, with widespread consultation and social support for “Energy Transformation”. Our group agreed with the Green Paper and the NESC report that citizens are in general, not aware of or do not understand the requirement for a transformation of our energy systems as they are not involved and engaged in the process. Targets have come from the top-down (Eu-rope) but citizens have no appreciation of what this means locally. The group felt national targets are important and that these need to be set on a local basis. It was felt that the level of political discussion does not reflect the gravity of the challenge posed by climate change and the security of energy supply. The group argued that allowing energy to be generated and owned locally would give citizens the opportunity to engage tangibly and without fear and opposition in new proposals.
Recommendation 1: Establish a national vision for 2050 through a wide consultation
process that engages society, the media and relevant organisations. Once the main
elements of the plan are accepted, this should be supported through local targets,
funding, marketing, and the required implementation plans by the relevant state agen-
cies. This Plan will guide the NEEAP and NREAP as the 1-5 year implementation of
the vision. This vision and Plan is in line with the German “energie wende” and the
Danish 2050 plan. The following could be considered:
o Host workshops (with bridging organisations) where the specific challenges and
international solutions are presented with detailed feedback from each group. A
focused media campaign should be completed in advance of this to inform as
many citizens as possible as to the nature of the consultation.
o Collated responses to the above workshops in addition to this document should
be presented in a detailed discussion document.
o The Dáil Committee for Communications, Energy and Natural Resources should
hold hearings on the energy plan, with appropriate media coverage.
o Primary legislation should be drafted to mandate the government and SEAI to
publish a 2050 plan, with an update every 5 years. This should inform all other
major energy related legislation, such as regional spatial and economic strate-
gies and county development plans.
Green Paper Submission Page 9 of 20
o DCENR should engage with relevant international expertise with experience in
energy planning to understand the main choices and required scale of any rele-
vant development that would seek to inform a consultation process. A peer re-
viewed and costed paper (Connolly 2014), on how to achieve a 100% renewable
energy Ireland by 2050 has been published. While the paper references not yet
commercially cost effective solutions for the 2035-2050 period, it calls for sensi-
ble widely deployed technologies for the next 10 years. This paper could inform
the study.
Recommendation 2: The NEEAP/
NREAP should have specific associ-
ated targets (and allocated resources
to deliver) that mandates engage-
ment in transformation policy and ac-
tivities.
o Renewable energy targets that
are enforceable through legis-
lation.
o Community Energy reduction
and generation programmes
should be marketed as a rural
economic regeneration tool. Specific targets set for Local authorities and local
development agencies to improve energy efficiency and renewable energy de-
velopment of their areas. This needs to be funded, mandated, trained and co-
ordinated to achieve targets and metrics.
o Funding intermediaries like energy agencies to technically support the switch to
sustainable energy.
o Acknowledge and reward those counties that implement innovative and effective
energy polices and to improve both their renewable energy generation, use and
energy efficiencies. This could be done in conjunction with the Energy Agencies
and could take the form of annual energy awards
2.2 Local and Community Development
Opportunity: Establishing a path for local and community led policy inputs and Leadership activities: The community examples from the group have shown that not only are top-down targets needed but ‘bottom-up’ solutions that will foster ownership by citizens and communi-ties. County Development Plans with associated renewable energy strategies can play an important role in the translation of national targets into locally agreed objectives and targets. South Tipperary County Council recently produced their Local Authority Renewable Energy Strategy (LARES) in accordance with the SEAI LARES methodology. The preparation of the RES was undertaken in partnership with, and with full engagement with the elected mem-bers. The Council during the preparation of the document, organised site visits to renewable energy developments, which proved very successful in ensuring the engagement of the elected members.
Figure 7 - DUET Engagement Workshop
Green Paper Submission Page 10 of 20
Recommendation 3:
There is potential for the
DECLG to produce
guidelines and method-
ologies for communities
on how to produce
Community Develop-
ment Plans with a signif-
icant focus on energy
development. All upcom-
ing Local Community
and Economic County
Plans should have a strong focus on energy reduction and renewable energy
generation objectives. This should include local resource identification, feasibility
for Energy Efficiency (EE) and Renewable Energy Sources (RES) projects for
communities. This specifically was the catalyst for Templederry Community wind
farm and a similar process for the Drombane Upperchurch Energy Team.
Recommendation 4: Local Authorities should be required to include Energy and
RES into the County Development Plan framework every 6 years to reflect the
dynamic nature of the sector. It should, however, be ensured that Local Authori-
ties are adequately resourced to meet this requirement.
Recommendation 5: Reducing the barriers for renewable energy development
through establishing a stakeholder task force (i.e. Cross-Departmental Commit-
tee). In Germany & Sweden the lead time for all consents is 26-52 weeks,
(Ecorys, 2010). In Ireland it is significantly longer. This would develop common
contracts, clear guidelines and remove unintended delays and obstacles, such
as:
o Produced revised Wind Energy Guidelines [under development],
o Consultation guidelines for developers,
o Set maximum grid delivery timelines where deep re-enforcement is not
required.
o Funding for ESB Networks for pre-feasibility studies for grid access.
o Standard Power Purchase Agreements (In Germany PPA’s are 3 stand-
ard pages, in Ireland 60-90 pages requiring significant legal fees to navi-
gate as standard)
o Alignment with permitting from state bodies to a one-stop shop (e.g. once
a grid connection is applied for, the Commissioner for Energy Regulation
(CER) and Renewable Energy Feed-In Tariff (REFIT) is part of the pro-
cess.)
o Service level agreements in terms of returns to and from statutory bodies
(e.g. National Parks and Wildlife Service, An Bord Pleanala, Aviation au-
thority, Health Service Executive, etc.).
Figure 8 - Elected Members Site Visits
Green Paper Submission Page 11 of 20
Recommendation 6: Consideration should be given as to establishing best
practice models with respect better community participation and/or ownership in
projects over a certain scale. This could take the form of a community engage-
ment plan. Minimum requirements could include:
o Dissemination Engagement: Early notification through parish newsletter,
parish announcement and local dissemination newsletter, social media,
local sports club announcement channels, etc.,
o Forms of Engagement: workshops, presentations and discussions
o Participation and Ownership: numbers of the local community engaged,
% of local population.
o Analysis: An independent socio-economic analysis of the project for the
area, so the local community can assess the project. It will review the
proposed sites and impact to surrounding areas.
o Independent technical advisor to be present at meetings.
Recommendation 7: LAs
could take a lead role in green
procurement. A 2011 green
procurement action plan (re-
quired as per (Com 2008)5) is
as of yet, not implemented.
SI151:2011 requires the use
of energy efficient procure-
ment. This is not evident as
being implemented widely in
the public sector to the group.
The group calls for full imple-
mentation of the Green Pro-
curement Action Plan and
SI151 to utilise the public purchasing power to lead the country in more sustaina-
ble energy use.
2.3 Supporting Sustainable Energy
Opportunity: Problem solving and entrepreneurial support: The latest NESC report outlines the need from national and international experience to have supporting organisations sup-port individuals, businesses and communities to aid the development of secure and sustain-able energy. Both the Tipperary Energy Communities and Templederry Community Windfarm group found significant challenges in implementing their community energy projects. A significant aid to their projects was the technical advice of the Tipperary Energy Agency and the com-munity development support of North Tipperary LEADER Partnership.
5 Communication from the commission to the European parliament, the council, the European economic and social committee
and the committee of the regions. Public procurement for a better environment, Com (2008), 400
Figure 9. Galway County Council's Wind Turbine at Carna Cill
Chiaráin Water Treatment Plant
Green Paper Submission Page 12 of 20
Community groups felt that it was important that the role of advisor and animator be sepa-rate to that of the planning authority as planning regulator.
Recommendation 8: Support community energy animation through the Local
Development Company and provide technical support through the local energy
agencies or equivalent independent experts.
Recommendation 9: There is a wealth of GIS data available, without one com-
mon platform. A combined Renewable Energy focused Geographic Information
System (GIS) software tool utilising DECLG’s MYplan.ie, Local authority e-plan
system, EPA’s Geo portal and SEAI GIS maps (Hydro, Geothermal, Biomass,
Wind Atlas). This could identify areas of high demand, high energy production
capabilities and restricted areas. This could provide the first level of feasibility
needed for development.
2.4 Ownership of Distributed Sustainable Energy Assets
Opportunity Ownership of Distributed Assets: Local ownership has significant socio-economic benefits, supporting the creation of a circular economy, decreasing imports of energy and decreasing exports of energy rev-enue. Local ownership engages citizens in energy decisions. The Department is request-ed to consider better support for local in-volvement and investment in renewable ener-gy projects, where appropriate.
Recommendation 10: Encourage
ownership of energy projects
through a local ownership require-
ment modelled on the Danish example. The Danish Equity Scheme requires de-
velopers to offer those living close to sites (within 4.5km) with turbines over 25m
an opportunity to purchase up to 20-per-cent shares. This means that those most
likely to be affected by a scheme will have the option to benefit financially. Under
the scheme, 20 per cent of every project has to be offered to local communities.
Recommendation 11: Consider the requirement of a share equity owner-
ship/community fund for local communities in significant renewable energy de-
velopments. This could facilitate community groups to access an equity share of
a development for a small up front annual payment. The current industry guide-
line of €1000/ MW/ annum represents a paltry 0.4-0.6% of a wind farms income
and is not sufficient to encourage communities to welcome a wind energy devel-
opments like they would an income generating development like a factory.
Figure 10 - Templerderry NS visiting their wind
farm
Green Paper Submission Page 13 of 20
2.5 Education
Young Citizens & Educational sector: The group recognised SEAI’s Primary Schools Pro-grammes plays a vital role in educating the younger generation. This needs to be extended to include post-primary schools. Young citizens need to be a part of local community devel-opment plans. School grounds could be used for RES so that young generations become accustomed to renewable energy. The group further felt that Third Level Institutes could help support community energy initiatives through academic placements and technical ad-vice. A further suggestion was for a nation-al register of local energy projects for which research solutions are sought.
Recommendation 12: Expan-
sion of the current primary
school education programs to
post-primary i.e. Green Schools
Programme.
Recommendations 13: Public
Schools to lead in RES and EE
deployment and to use these
developments as educational
tools for improving the engagement of future energy citizens.
Recommendation 14: There is scope to support third level institutes for practical
research topics with an innovation voucher type programme for the public and
community sectors targeted at energy. A model similar to the TEAGASC Walsh
Agriculture scholarship programme6 could be implemented where a reasonably
large number of sustainable energy related PhD’s per annum could be funded,
using ideas from public, private and community sectors.
Recommendation 15: Continued support for the ocean energy research plan, to
establish Ireland as a leading ocean energy hub.
Recommendation 16: Increase the funding for energy and climate related re-
search via the research organisations. (E.g. Science Foundation Ireland, Envi-
ronmental Protection Agency, Science Gallery, SEAI etc.)
Recommendation 17: The roll out of smart metering needs to reflect on the un-
successful nature of the initial trials in engaging citizen behavioural change.
(Foster & Mazur-Stommen, 2012) Rolling out smart meters without addressing
this concern may result in ignoring or worse not trusting and treating the smart
meters like the current roll out of water meters:
6 http://www.teagasc.ie/research/postgrad/
Figure 11 - Borrisoleigh Boy NS learning about Climate
Change and Energy
Green Paper Submission Page 14 of 20
o Focus research on effective communication techniques and behavioural
drivers. e.g. Immediacy of response.
o Software engineers and demand side managers need to engage with
communication experts to ensure that the technology drives behavioural
change.
o A successful pilot, where the measure of success is the engagement with
citizens, rather than the technology communicating with the grid. This
should be required in advance of the Department authorising further roll
out.
o The technology should engage with on-site generation to ensure that any
(e.g. PV) onsite generation signals appropriately inside a dwelling to
switch on or off appliances/ drive behavioural change.
o Ensure technologies can seamlessly interact with smart meters(e.g.
freezers pre cooling and shutting off during peak prices)
2.6 Penalties and Incentives
Socio-economic supports for energy efficiency and renewable energy: National supports
like exchequer funding through grants have, as the Green Paper explains, proved vital in
encouraging the sector. Countries that have been relatively successful in implementing RES
like Germany, Denmark, and Austria have higher carbon tax regimens and funding (REFIT
& Grants) to help encourage RES integration in the energy system. The Upper Austrian Re-
gional Government Energy Agency has led an improvement from 2 to 50% RES heat over
20 years. The simple message that is often used is “Carrot, Stick and the Tambourine”. The
“stick” is the taxation of the fossil fuel. The “carrot” is the funding, encouragement, regula-
tion and fiscal supports while the “Tambourine” is the full suite of enabling actions like ad-
vertising, technical support, workshops, public meetings, etc.
Recommendation 18: Consider the use of increased carbon tax in a transpar-
ent, planned manner in order to achieve RE targets. This should be completed in
a manner that protects the vulnerable and does not unduly impact businesses
that export through use of rebates/ funds. Failure to achieve targets should see
the rate of carbon tax increasing. A clear long term transparent carbon tax infla-
tion methodology should be utilised that reflects the UK’s REFIT system that de-
creases REFIT as targets are achieved.
Recommendation 19: The current Public Service Obligation (PSO)7 levy is a
transparent method of supporting key goals in the energy system. The effects of
7 The PSO levy is a subsidy charged to all electricity customers in Ireland. It is designed by the Irish Government
and consists of various subsidy schemes to support its national policy objectives related to renewable ener-gy, indigenous fuels (peat) and security of energy supply. The proceeds of the levy are used to contribute to the additional relevant costs incurred by PSO-supported electricity generators which are not recovered in the electricity market
Green Paper Submission Page 15 of 20
the PSO are not clear to the general public. Each utility bill should include the ef-
fect of the PSO in terms of market pricing, i.e. the PSO increased your bill by €X
(LEVY) but decreased it by €Y (Effect). We also need to spell out the security ef-
fect of the capacity supports under the PSO.
Recommendation 20: An “Energy Independence Budget”, funded through ener-
gy levies or taxes (i.e. PSO/ Carbon tax) should be published to show how it will
be used .i.e. income, expenditure and value for money.
Recommendation 21: Incentivise investment in more energy efficient houses
through a Property tax discount based on BER rating of the house in line with the
VRT and Motor tax systems. Trust in taxation systems will be improved if it is
linked to grant supports to achieve a lower tax band.
Recommendation 22: Fair and secure tariffs for community projects. Communi-
ty projects need additional tariffs to overcome the administrative cost associated
with Single Electricity Market (SEM). Given the scale of community projects, they
suffer adversely for the size of project. The tariff structure in Ireland is built for
large developments. A similar tariff structure to that of Germany will encourage
more community RES.
Recommendation 23: Better supports for local micro-generation proposals i.e.
through payment for generated excess (i.e. mandatory off take agreement8) from
suppliers at an appropriate rate, with minimal red tape. The scale of the allowable
size should be appropriate for domestic and where commercial and industrial
premises complete a real autogeneration project (electricity substantially used on
site). The rate should reflect a combination of the following pricing:
o Market price for energy (5.5-6.5c/kWh)
o Reduction in transmission losses (0.3-0.7c/kWh)
o Carbon reduction at a long term appropriate price of carbon i.e. not the
failed EU ETS price. A price of €50-€100/ tonne should be appropriately
applied (i.e. 3-4c/kWh)
o The value of decreasing energy imports on the balance of trade. (0.1-
0.3c/kWh)
o The socio-economic value of the construction and installation of the solar/
wind installation. (0.5-1c/kWh).
o Total 9c/kWh to 12.5c/kWh
8 An agreement between a producer of a resource and a buyer of a resource to purchase/sell portions of the
producer's future production. An offtake agreement is normally negotiated prior to the construction of a facili-ty such as a mine in order to secure a market for the future output of the facility. (http://www.investopedia.com/terms/o/offtake-agreement.asp n.d.)
Green Paper Submission Page 16 of 20
Recommendation 24: Government support for the initial feasibility, research
phase, community energy plans and capacity-building. This is how North Tipper-
ary LEADER Partnership helped Ireland’s only community owned wind farm,
Templederry Community Wind Farm in County Tipperary. The Scottish govern-
ment has recently opened an energy support office with a £10m community fund
(National Economic and Social Council, 2014). Germany has a National Office for
Energy Co-operatives. 9
Recommendation 25: Introduce flexibility into the time allowed for completion of
annual sustainable energy programmes at public and community levels. (e.g.
Better Energy Communities). There should be a minimum of 12 months from
date of offer of support for implementation. Community groups, The Local Au-
thority and Energy Agencies find the current 3-4 month window of implementation
highly restrictive leading to lower ambitions, higher costs and greater risks.
Recommendation 26: Encourage tax efficient structures for local ownership of
energy projects – as per Danish model where income earned up to a point from
community renewable energy is tax free. Currently, the Irish Revenue allows
people to write off tax when investing in “business expansion”. This could be a
significant additional incentive for community owned energy projects.
Recommendation 27: State-loan guarantees for public good and community
projects, particularly local authority led district heating projects, increased credit-
union support and a national fund for public investment. (National Economic and
Social Council, 2014). This is standard in Denmark, Sweden and Austria where
co-operative (user owned) district heating installations have a state guarantee to
decrease their investment interest rate.
Recommendation 28: Establish a system of certified green energy credits and a
guarantee of origin, similar to the UK so that citizens can buy verified green elec-
tricity.
Recommendation 29: A range of Electric Vehicle (EV) supports to launch the
sector. Including:
o No car tax 5+ year guarantee for first 50,000 EV,
o legislation to protect EV parking spaces,
o Guaranteed toll free for EV until 2020.
o Support for Public Sector organisations to increase the numbers of EV in
their fleets to 2020 (excluding heavy machinery)
o Obligation on all vehicle fuel sales outlets to install fast charge points by
2016 (paid for by their fuel sales on fossil fuels).
9 http://www.dgrv.de/en/home.html
Green Paper Submission Page 17 of 20
o Support for all public service and employee car parks to install charging
points based on the size of the car park (paid for by carbon tax on road
fuels).
Recommendation 30: Facilitate the full implementation of the Bioenergy Strate-
gy 2020 and the recently published REFIT for heat, Renewable Heat Incentive
(RHI). The RHI should be scaled appropriately as per the UK’s RHI with increase
or decrease triggers based on whether targets are achieved. Targets should be
based on achieving 100% RES energy by 2050.
Recommendation 31: Increase the number of public buildings that are supplied
by renewable energy or HECHP based on achieving 100% RES-H/ HECHP by
2020. This could be achieved utilising the RHI and a requirement to have a RES
feasibility study as part of required energy audits. Tipperary County Council sup-
plies over 60% of it’s heat energy by RES-H/ HECHP and all installations are cost
effective.
Recommendation 32: Improvement of the cost effectiveness of Anaerobic Di-
gestion through reducing costs of regulation or increased supports. A separate
IRBEA submission on Anaerobic Digestion will be made.
Recommendation 33: Support for domestic retrofit renewable energy technolo-
gies: Heat pumps with low temperature radiators, domestic pellet boilers. Cessa-
tion of supports for fossil fuel boilers immediately recognising their success in
achieving the switch to condensing boilers in 2007/8.
Recommendation 34: Support the phase out of the sale of fossil fuel boilers on
a phased basis starting with new build in 2015, retrofit oil in 2016, and retrofit gas
in 2017.
Recommendation 35: Definition of Nearly Zero Energy Building (NZEB)10
for
new and retrofit buildings to the full intent of the Directive (2010/31/EU Article 9).
Recommendation 36: Consider the Implementation of a pay-as-you-save retrofit
program with 0% finance and grant support where the applicant achieves Nearly
Zero Energy Building (NZEB) status. This (as yet undefined) could be a minimum
energy reduction of e.g. 40%-60% and a minimum renewable energy supply of
e.g. 50%.
10
Nearly zero-energy building’ means a building that has a very high energy performance, as determined in accordance with Annex I. The nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby - Directive 2010/31/EU Article 2.2
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:153:0013:0035:EN:PDF
Green Paper Submission Page 18 of 20
Recommendation 37: An NZEB implementation plan (as defined above) for fuel
poor and social housing should be completed with appropriate supports. Coun-
tries such as Belgium, Austria and Germany have utilised carbon taxes in con-
junction with European Investment Bank funding as supports for their projects.
2.7 Regulation and Administration:
The group felt that there were plenty of ideas and enthusiasm within local communities.
However, they felt that there was insufficient support and that there were regulatory barriers
impacting on progression of projects. The group felt that key infrastructure is lacking to
achieve deep RES integration. Such infrastructure includes District Heating (DH).
DH has proven to save fuel by utilising waste heat in the energy system from power plants
and industry. DH utilises more renewable en-
ergy by using heat from solar thermal and ge-
othermal energy and saving money by using
less fuel, by reducing the thermal capacity
necessary in the heat sector (Connolly 2014).
Madlener, (2006) has empirically estimated
that per €M invested in the Biomass District
Heating plants built in Vorarlberg Case study,
has a resulting value added of €1.1 million to
the local economy and the employment effect
of 18 person-years.
Recommendation 38: Flexibility
and priority needs to be incorporated into regulations for planning permission,
grid access, and grant application. A reciprocal feedback approach needs to be
adopted for community groups. (Ecorys, 2010)
Recommendation 39: Expand the current programme for non-gate process ap-
plications to the electricity grid for small community owned or public good pro-
jects.
Recommendation 40: Consider better means of decreasing the time between
gird offers and grid offer take up. Secondary trading of grid connection applica-
tions should not be allowed without reverting to the state. Developers should not
make windfall profits on access to the grid.
Recommendation 41: Implementation of the wood fuel quality assurance
scheme as part of the renewable heat incentive.
Recommendation 42: Improved certification and training for installers of all re-
newable and sustainable energy technologies should be implemented utilising an
independent regulatory and certification scheme similar to OFTEC and RGI (Oil
and gas certification schemes).
Figure 12 - Local Tipperary Biomass Company explain-
ing about the supply chain to Minster O'Dowd
Green Paper Submission Page 19 of 20
Recommendation 43: Improved implementation, enforcement and education of
the Eco-design (2005/32/EC) and Energy labelling (2010/30/EU) directives
through full implementation of the directives. An effective marketing and en-
forcement campaign is required.
Recommendation 44: Decrease the cost of certification of sustainable energy
products and services through use of pan European certification schemes. Na-
tional Standards Authority of Ireland (NSAI) should be challenged with adopting
UK and EU certification schemes in advance of any Irish specific schemes. E.g.
Annual Costs of airtightness testers in Ireland are 10-15 times the UK equivalent.
Recommendation 45: Adopt a comprehensive support program for District heat-
ing from renewable energy. This will allow excess wind energy be stored as
thermal energy and bioenergy to be used sustainably and competitively. The
Government is mandated to complete a comprehensive analysis on district heat-
ing under Art 14 of the Energy efficiency directive, the group calls for this to be
completed as soon as possible. Consideration should be given to adopting the
Austrian framework that has been successful in implementing Biomass District
Heating (BDH) which included:
o Capital grant for BDH systems with a min capacity installed.
o State loan guarantee for the DH companies to access low cost finance.
o Grants for local prefeasibility studies
o Capital grants of up to 35% for connection to DH for house holders.
2.8 Moneypoint
The Green Paper sought specific views on the future of Moneypoint in Ireland’s future gen-
eration mix. As most large power plants have a 40 year lifecycle, the question should be
about whether it is in line with the International Energy Agency (IEA) 80% carbon reduction
by 2050 or other international guidance. The group feels that the unacceptable nature of
coal without carbon sequestration should be the governing factor for any decision.
Recommendation 46: The group advises that 10-15 small to medium (15-
30MW) scale biomass fired CHP located close to main population centres that
fully utilises waste heat would be significantly more sustainable, secure and soci-
oeconomically advantageous, even if a portion of the fuel was imported.
Recommendation 47: The transmission assets associated with Moneypoint
could be utilised to transmit Ireland’s ocean energy of wave tidal and floating off-
shore wind energy potential to Dublin. These are recognised as yet pre-
commercial technologies, but should be included in any analysis as money point
comes to the end of it’s lifecycle. Clare, Limerick, Galway and Kerry could be-
come hubs of ocean energy development for Ireland and Europe.
Green Paper Submission Page 20 of 20
3 Conclusion
The group would like to thank DCENR for the opportunity to respond to the consultation. The main points in the submission as outlined in the summary can be seen in action in other European countries. The imperative for action is clear with almost all arguments support-ing the case for a concerted effort to fundamentally shift our economy to an efficient renewably powered economy:
Competitiveness and the circular economy by decreasing our €6.5Bn energy bill.
Security of supply and energy in-dependence from middle - east-ern and Russian fossil fuels.
The impending crisis of climate change driven predominantly by fossil fuel use.
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Public procurement for a better environment.
Connolly, D. (2014). A technical and economic analysis of one potetial pathway to a 100% renewable
energy system. International journal of sustainable energy planning and managment, 1, 7-
28.
Ecorys, E. E. (2010). Assessment of Non-Cost Barriers to Renewable Energy Growth in EU Member
States—AEON.
http://www.investopedia.com/terms/o/offtake-agreement.asp. (n.d.).
Madlener, R. (2006). Innovation diffusion, public policy, and local initiative:The case of wood-fuelled
district heating systems in Austria. Elsevier.
National Economic and Social Council, . (2014). Wind Energy in Ireland: Building Community
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Figure 13 - The next generation/s is who this is all for