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.

4 Bibliography

Berkes, F. (2009). Evolution of co-management: Role of knowledge generation, bridging. Journal of

Environmental Management 90 , 1692–1702.

Commission, E. (2008). 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.

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

Energagment and Social Support.

Scheer, J. (2012). Alleviating Energy Poverty in Ireland – An Efficient Approach for Future

Government Ex-penditure. MSc submitted to Trinity College Dublin.

Figure 13 - The next generation/s is who this is all for