Renewable Energy Export and Development Policy Submission

Submission to Irelands renewable energy export and development policy


Name: Theresa Carter

Brief bio

Co-founder and co-ordinator of LEAF – Laois Environmental Action Forum. A transition hub, forum for sustainable development and environmental stewardship on Laois.

Co-founder and convener of LEN – Laois Environmental Network. A policy focused network for Environmental Pillar appointed environmental representatives on boards and bodies within Laois.

Participant in the OGP process – Open Government Partnership. We are currently negotiating a National Action Plan with Minister Howlinʼs staff.

Facilitator of the Powerdown Show. A course designed to enable communities embrace and design their transition in a fossil fuel free future.

Co-founder of Transition Ireland and Northern Ireland. The network for communities in transition to a lower carbon future.

Member of the National Aarhus Convention working group.

Breakdown of Submission This submission is broken down into three sections:

1 Observations and critique of the departments introduction to, information document and policy framework. They clearly indicate that these plans are advanced way beyond the time for public participation.

2 Proposals for inclusion in the policy document. These proposals are compiled from feedback on years of Powerdown Courses and events hosted by LEAF.

3 Detailed bio to demonstrate my experience with community education and awareness raising in the energy transition and closing comments.

1 Observations and critique of the departments introduction to, information document and policy framework. They clearly indicate that these plans are advanced beyond the time for public participation.

Obvious omissions by government as to the role of the public in planning relevant to their environment.

Below is the introductory text on the departments site. The wording I would expect in a transparent, inclusive consultation is in bold. Their exclusion provides insight into the lack of consideration of the public. It implies to me that key decisions have already been made prior to this consultation. +Development+Framework.htm

The Government proposes to consult the public with a view to optimise the opportunities for export of renewable energy from Ireland to other member states of the European Union, in the first instance to the United Kingdom should this be the consensus, in accordance with European law, including Directive 2009/28/EC: On the promotion of the use of energy from renewable resources. (Why implicate Europe – this serves only to further drive the public away from a united Europe, Each member state is responsible for it’s own actions)

To help achieve this goal, the Department of Communications, Energy and Natural Resources is developing a Renewable Energy Export Policy and Development Framework (with a spatial dimension) for renewable export opportunities from Ireland, in the first instance to the United Kingdom if deemed the wishes of the public as stated, with particular focus, if that be the consensus, on large scale projects for renewable energy generation.

Development of the Renewable Energy Export Policy and Development Framework is to be informed by the carrying out of a Strategic Environmental Assessment (SEA). This will be accompanied by a Habitats Directive Assessment [or Appropriate Assessment (AA)] under the Habitats Directive 92/43/EEC, and widespread consultation with the public and stakeholders.

The process will take as much time as is required (approximately 12 months ) and consist of three main stages. During each of these stages, consultation will be undertaken with the public, stakeholders and certain statutorily designated organisations.

The process would have taken 12 months before the ratification of the Aarhus convention but it will now take as long as is necessary to accommodate adequate information and awareness raising to ensure meaningful and facilitated public participation. This process must lead where previous plans have failed – it must be participatory and public participation must be facilitated.

Observations and questions on the information document:


The availability of energy is one of the most fundamental requirements for our day to day activities. The demand for energy, worldwide, has increased greatly, but the large scale use of finite coal, oil and gas resources (known as fossil fuels) is changing the earth’s climate, with potentially serious impacts. The European Union has addressed these issues by encouraging all member states to develop and exchange renewable energy resources.

This entire paragraph begs the question “Why are we prioritising to generate energy to export when we need it ourselves with an expected rise in demand?” It must also be queried how are we supposed to afford diminishing stocks of fossil fuel as the prices rise with dwindling availability. Maintaining our own dependency on fossil fuel will inevitably mean higher levels of fuel poverty and an inequitable society. It makes good economic and ecological sense to secure a renewable energy supply for our domestic market to sustain our own economy first.

The development of renewable energy is central to overall energy policy in Ireland, as set out in the Strategy for Renewable Energy 2012-2020. The strategy is set firmly in the global and European context, aimed at fundamentally de-coupling energy from reliance on fossil fuels, which are increasingly being sourced from outside the borders of the European Union. Renewable energy reduces dependence on fossil fuels, improves security of supply and reduces greenhouse gas emissions. This creates environmental benefits, while delivering green jobs to the economy, thus contributing to national competitiveness and the jobs and growth agenda. The availability of indigenous, sustainable power is a valuable national asset and it is essential that in developing it that we maximise its return to the state.

The National Renewable Energy Action Plan was devised with minimal consultation. As a citizen of this country, actively engaged with education about climate change and fossil fuel availability I would have contributed to that plan. I was ignored and not given the opportunity to engage with the process. This is fundamentally wrong and no further plans should be made on top of that flawed plan. This export policy must not be drafted until there has been a review of the NREAP – Strategy for Renewable Energy 2012-2020.

LEAF and COF – Claiming Our Future co-hosted an event to begin the process of creating A People’s Charter on Renewable Energy on November 9th 2013. The first step in this process is the call for a review of NREAP so that public participation can be accommodated. There is now a live petition to that effect and I would urge the government to consider addressing the exclusion of the public in the strategy 2012 – 2020.

EU Directive 2009/28/EC: On the promotion of the use of energy from renewable resources, sets targets for each EU member state, to be achieved by 2020. In the case of Ireland, a non-legally binding target requires that at least 40% of electricity is to come from renewable energy by 2020 to achieve Ireland’s overall legally binding target of 16% of our

energy requirement to come from renewable sources by 2020. The Directive also outlines methods by which member states can coordinate on achieving targets.

Due to our location and climate, in Ireland we have huge renewable energy potential, particularly from wind and, in the longer term, from wave and tidal power. It has become clear that Ireland’s wind and ultimately ocean resources can deliver significantly greater volumes of energy than our domestic market can absorb. There is great potential for Ireland to become a renewable energy exporter within the next few years.

The Government has recognised this export opportunity in the Strategy for Renewable Energy 2012-2020, and seeks to support the export of renewable energy to other member states of the EU, on condition that it is of clear and significant benefit to the Irish economy and with no net cost to the Irish consumer. The Strategy for Renewable Energy 2012-2020 sets out certain goals, including the achievement of progressively more renewable electricity from onshore and offshore wind power for the domestic and export markets. It states that there are market possibilities for onshore wind projects of significant scale, which may in time offer the potential for the development of export to the UK market directly from the island of Ireland. The Government is committed to implementing the actions outlined in this strategy so as to ensure that this export opportunity can be realised. The potential benefits of a wind and ocean energy industry of scale are significant at both national and local levels in terms of jobs, investment, potential interconnection benefits and revenue for the state.

Again I must state that the Strategy for Renewable Energy 2012-2020 is non consultative and devised without public participation. It should not be used as a base for anything until meaningful public participation has been facilitated and incorporated.

In January 2013, the Minister for Communications, Energy and Natural Resources, Mr. Pat Rabbitte, signed a Memorandum of Understanding with the United Kingdom, which commits Ireland and the United Kingdom to conducting an evaluation of how Irish renewable energy resources can be developed for the mutual benefit of both countries in line with relevant EU Directives, and to explore opportunities for renewable energy trading, with the objective of entering an Inter-Governmental Agreement in early 2014.

Can you please tell me the public consultation that took place in the decision to sign a memorandum of understanding with the United Kingdom?

Development of the Renewable Energy Export Policy and Development Framework is to be informed by the carrying out of a Strategic Environmental Assessment (SEA). This will be accompanied by a Habitats Directive Assessment [or Appropriate Assessment (AA)] under the Habitats Directive 92/43/EEC, and widespread consultation with the public and stakeholders.

The initial study area for the export policy and development framework is the entire State. Following preliminary scoping and Strategic Environmental Assessment, it is intended that the export policy and development framework will: • Set out a clear national policy context for the export of renewable energy;

• Broadly identify strategic areas in Ireland for renewable energy generation for export; and

• Provide guidance to planning authorities, including An Bord Pleanála, when considering any proposals for renewable energy export.

• This will include guidance to planning authorities, in consultation with the Department of Environment, Community and Local Government, on the preparation of appropriate development contribution schemes for such types of development.

The public consultation on such an important issue must be comprehensive and as far reaching as possible. It must be organised by a body independent of the department and underpinned by the Aarhus convention. The public must be involved in this process from the earliest possible moment. It is apparent that this has not been the case leading to widespread discontent and anger at proposals. The way that the midland wind projects have been introduced to the public has been detrimental to all future attempts at renewable energy production.

The main principles underlying the policy and development framework will include: 1. Maximising the sustainable use of low carbon renewable energy resources; 2. Any trading of renewable energy between member states must be sustainable in the long term and reduce dependence on fossil fuels;

3. Fostering economic growth and increasing investment and employment opportunities; 4. Achievement of Irish renewable energy targets not to be compromised; 5. No net cost burden on the Irish consumer;

6. Long term improvements to infrastructure in Ireland; 7. Any infrastructure built is to facilitate interconnection to other European member states, either immediately or in the future, with minimum disruption; 8. Protection of the natural, built and cultural environment, particularly residential amenity, to be a priority; and 9. Provision of real community gain or benefit to be essential.

This should include a desire to ensure compatibility with community plans and their wishes for their own area.


Public consultation is considered a key element of developing any policy or plan to ensure the opinions and views of individuals and interested parties are taken into consideration at the earliest stage possible of a policy/plan making process.

If consultation is considered a key element then why has it been left so long and it’s remit decided at departmental level?

Specific factors for consideration

Economic benefit

How will Ireland benefit from the proposed export project? A Cost Benefit Analysis is currently being carried out on the proposed project which will be taken into consideration in the development of the Inter-Governmental Agreement and policy and planning framework.

This paragraph confirms that there is already a “project”. In order for a project to begin it must comply with the relevant policy. If the policy is only in itʼs first phase how come a “project” exits? There has been no input from the public in the preparation of an export policy until now so how can a project be advanced enough to be analysed?


What is the cost benefit analysis being carried out on? What is the project? Who was consulted in the planning of this project?

I have requested this information, twice from the contact email, to inform myself in preparation of this submission but received no reply.

Due to the fact that I was not sent the relevant information I sought I emailed the Minister today, the final date for submissions, Nov 22nd. Details as follows:

Dear Minister

I made a request on November 17th, for information I need in order to complete a submission on energy export policy, due to your department today. I received acknowledgment of receipt but not the information requested. I sent the request again this time with reference to the Aarhus convention and I still have no reply.

I did receive a reply to my request for printed information documents on November 12th – the same day I sent the request so I am aware that this email address is monitored and responded to.

I would like to know why this information is not being made available. I also need it today, as soon as possible in order that I make an informed submission.

Kind regards Theresa Theresa Carter

Begin forwarded message: Date: 18 November 2013 15:19:02 GMT To: Export <> Subject: Fwd: Cost benefit analysis – Access to information under the Aarhus Convention


Further to the email I sent yesterday requesting information on the cost benefit analysis underway on a proposed renewable energy project referred to in the departments information document for this consultation, which I have printed and saved, I respectfully request that under the Aarhus Convention I am entitled to this information.

Can you please let me know when I can have it? I need it in order to make an informed submission so as soon as possible, given that submissions must be entered before Friday.

Kind regards Theresa Theresa Carter


Begin forwarded message: Date: 17 November 2013 19:14:17 GMT To: Export <> Subject: Cost benefit analysis


Could you please email me details of the cost benefit analysis currently underway as per the information document table of considerations.

Economic benefit How will Ireland benefit from the proposed export project? A Cost Benefit Analysis is currently being carried out on the proposed project which will be taken into consideration in the development of the Inter-Governmental Agreement and policy and planning framework.

Kind regards Theresa Theresa Carter

Renewable energy resources

What type of resources should be considered for the generation of electricity for export? Ireland has a vast amount of renewable energy resources from wind, wave, tidal, bio- energy and solar. However generation of electricity from some renewable energy resources is more advanced than others. On-shore wind energy generation is currently the most advanced and economically viable technology. It is important to ensure that a mix of renewable energy resources is maintained in Ireland in order to ensure a constant supply of energy from renewable sources.

“It is important to ensure that a mix of renewable energy resources is maintained in Ireland in order to ensure a constant supply of energy from renewable sources.” Therein lies the answer to the question. What resource is harvested where is subject to consensus. Another question this provokes is who is the constant supply to be ensured to – export or domestic consumption? Is there any consideration given security of domestic supply?

Grid options

How will the power be exported to the UK? Will the existing grid be utilised or will new infrastructure be constructed exclusively for the export of energy? Where will the landfall points be along the Irish coastline? Grid principles are being established to ensure that any new development will complement the Irish grid infrastructure.

The obvious assumption is that there are to be landfall points along the Irish coastline. Is this an attempt to have the public inform your dilemma or that of the “project” developers? When the public have had their say on a national strategy including export and if they deem export an option, then they should be asked about landfall points.

The following proposals are my personal recommendations.

2 Proposals

Economic benefit

Renewable energy from wind, the sun and water are assets of the inhabitants of Ireland collectively and should not be made available to privatisation. They are national treasures.

Wind, for example, is a collective asset, it is part of the commons, available to all citizens. Wind turbines affect the velocity and flow of air. The presence of industrial wind developments would mean that any attempts to erect a domestic or community scale turbine in the vicinity would be futile as the wind will be affected by the larger turbines – basic physics.

The only acceptable economic benefit is a share of the energy in the county or community boundaries where it is harvested. It makes no economic sense to export our renewable energy and pay the inevitably rising costs for fossil fuels.

Renewable energy resources

It is important to ensure that a mix of renewable energy resources is maintained in Ireland in order to ensure a constant supply of energy from renewable sources.

This sentence echoes feedback from all workshops and events hosted to consider our energy transition. However the paramount action is conservation. There is no point in generating renewable energy to waste it.

It is essential that the resource used is compatible with the area it is generated and accepted by the community.

The following is a snippet of feedback from the Nov 9th event which is a taster of the publics perception of renewable energy resources. A more detailed document is available.


Group 1

• •

Need for community cooperatives


o o

Group 2

Eirgrid/esb grid connection

Need for network in each local community group Towns need to trade their own energy Ireland is following the UK Model


Free to small scale anaerobic digestion

Unsustainable Need to follow more appropriate country like Denmark or Austria.

Systems thinking approach to renewable energy and other resource use Group 3 – Combined Heat and Power

High investment/capital cost


Quick payback (2-3 years depending on site) Retrofits are difficult and costly


o o o o

Perfect for new building sites Can run on many types of fuels

Group 4 – Solar Energy

• •

Solar for H/W and electricity Lots of potential for solar PV but needs stimulation from policy


o o o

LPG Methane Nat Gas Biomass

High efficiency on the unit


80-90% Sizing of unit the most important aspect when installing or planning

Feed-in tariffs Solar Thermal

Group 5 – Wind

• • •

Is wind an efficient production method Regulation of industry? Enabling community ownership



Technically proven in Ireland 10,000 installations Will continue to grow slowly unless access to capital

 Pay as you save  Energy performance contracts





Remove all energy subsidies Tax carbon at all levels Invest money in mix of renewables Empower active citizens into energy independent communities Power to choose

Structures Group 5 – No name

• • • • •


Right to refuse

The generation of energy for export should take place wherever the generation for domestic use takes place. Only when domestic need is met should export become significant.

Grid options

The existing grid will have to be utilised if domestic supply is deemed paramount. These questions are premature given that the NREAP has not been revised to include public participation. Only when people have agreed that this is the future of renewable energy in Ireland can the decide the most logistical positions for infrastructure. To exclude them from the decision making so early on was a strategic mistake that will hinder any progress.

The national grid is a strategic infrastructure and asset to the country. All developments should be included in our national grid. It is of no benefit to this country to devise a completely independent infrastructure for exporting a natural resource of this country.

Community benefit

Community benefit should be security of supply and reduced energy costs. Any development of renewable energy in Ireland MUST incorporate domestic supply first and foremost. It is the only gain that will work in line with the variance in energy costs. No fixed amount of token “gain” will compensate for a stark rise in energy costs. There is no point in having a new hall if the community canʼt afford the oil to heat it.


The impacts of climate change are becoming more frequent and devastating and the IPCC report 2013 advises that all reserves of fossil fuel be left n the ground. Fossil fuel makes up 92% of Irelands fuel input, mostly imported. In 2011 Irelands import dependency was 88% with a cost of 6.5 billion euro.

We need a long term vision and innovative approach to Irelandʼs energy future – which must mean a radical transition from fossil fuel. We must agree this plan collaboratively. This means better communications between the public, the state bodies and potential investors. Devising a strategy as significant as the national renewable energy strategy without consulting the public is not the right approach. People want to have a say in their energy future and people do have a vision. Having hosted numerous community events I suggest that the department think seriously about revisiting the 2012-2020 strategy and generate a shared vision that has a much better chance of success than the current process.

While developing the Peopleʼs Charter on Renewable Energy we have four base assumptions:

• Communities MUST be involved • Renewable energy needs to be developed to reduce our dependency on fossil fuels • Fuel poverty needs to be addressed, guided by the principals of equality • Climate Change must be addressed.

These are the four principals under-pining the peopleʼs charter. The reality is that the governmentʼs charter should be the same. The Department of Communications, Energy and Natural Resources should engage in meaningful discussions and facilitate a collaborative approach to renewable energy in Ireland.

3 Detailed biography

I am currently the coordinator of LEAF and a member of the national working group on the Aarhus Convention. I am also participating in the Open Government Partnership process. I value public participation as THE most important factor in the success of any initiative. To have created a national policy without seeking input from the public is a major breech or power and responsibility. To make assumptions about energy solutions for the country, including plans to export, really does make an mockery of democracy. It shows complete disregard and contempt for the public.

I helped establish the Transition Network in Ireland, namely Transition Ireland and Northern Ireland – TINI. This is a grassroots movement designed to encourage the transition to renewable energy and sustainable local economies. In my role with TINI I coordinated a briefing on peak oil in Leinster House in 2011 and would have been working on that when the National Renewable Energy Action Plan was being devised.

I have been involved in community based education on climate change and resource depletion for over 6 years. I facilitate the Powerdown course, a community resilience course designed by Cultivate based on the challenges posed by climate change, peak oil, the impact these challenges have on our economy and day to day living.

I was a member of Laois County Development Board for 3 years as the voluntary environmental representative appointed by the Environmental Pillar. It was while in this position that Laois Environmental Network, LEN, was established by the environmental reps on various policy and decision making bodies in the county. This led to the establishment of LEAF – Laois Environmental Action Forum, which is a regional transition hub as well as a forum for sustainable development and environmental matters in Laois.

I have been involved with many policy submissions and proposals in my role within LEN and do a lot of work with the Environmental Pillar. I am currently coordinating their Aarhus Convention Roadshow.

Closing comments

Despite my extensive work on the transition to renewable energy and sense of responsibility as an active citizen, I was not given the opportunity to contribute to the Strategy for Renewable Energy 2012-2020. This is a major failing of our government and totally dictatorial in itʼs attitude and contempt for the public. Apart from general observations in a submission to the Framework for Sustainable Development in Ireland, this Renewable Energy Export and Development Policy is the first time that I have the opportunity to have my voice heard, at a national level, in Irelandʼs transition from fossil fuel. I can safely say that is extremely unsatisfactory for such an important policy and I challenge the government to review the Strategy for Renewable Energy 2012-2020 in order that extensive awareness raising and public participation is facilitated.

Due to the lack of consideration government gave to the public when it created itʼs flawed renewable energy policy my role as a renewable energy advocate has been undermined and I am now subject to verbal attacks. The way in which it was introduced that industrial wind farms are planned for the midlands has completely destroyed any trust and momentum to transition to renewable energy that did exist. Whether that is the government and industries plan remains a mystery but either way it has given rise to polarisation and community breakdown.

The contents of this submission are observations and recommendations for the energy export policy. Given my extensive experience in renewable energy advocacy and fact that I live in the midst of the midlands I advise that you heed this submission.

As well as calling for a revision of the Strategy for Renewable Energy 2012-2020 I request that this process include oral hearings and regional consultation clinics much like the constitutional convention and CEDRA process.

While this submission is personal it has been made available to members of TINI, LEN, LEAF, The Environmental Pilllar, the National Aarhus Working group and OGP.