Context

In the beginnings of the modern era of environmental protection, roughly 1950-1980, and continuing for several decades, the focus was on the environmental damages inflicted by modern industrial, business and agriculture practices. The creation of synthetic chemicals during the two world wars and their use, abuse and disposal triggered this focus. Not many talked about energy in those days, except to condemn nuclear after Chernobyl in 1986.

Now energy is the rage. With climate change taking center stage, we are learning that the environmental problems unfolding are being inflicted by all of us, not just the usual corporate suspects. We all use the fossil fuels and other sources of greenhouse gases (GHGs). At the center of the climate change discourse is the issue of energy sources, as we, especially the developed countries, have relied on cheap fossil fuels to drive our cars, heat our homes and fuel our economy and no one can do that anymore, without disastrous consequences.

Ireland is now proposing to address this central challenge first in a a Green Paper on the topic that was issued in May 2014 and was the subject of public consultation until July 31.   The government will now take under consideration the public comments submitted in writing, and publish at some time a White paper on Energy Policy in Ireland, perhaps following further consultation with stakeholders or the wider public.

We have not hesitated to criticise the Irish government’s failed efforts to develop other environmental policies or regulations (e.g., for climate adaptation) so we should not hesitate to credit the agency, and its staff, when they offer something substantial, as they have here. We can be hopeful that the White Paper provides a substantive, broadly supported low carbon energy policy but we do need to remain vigilant for the process that follows this Green Paper.

For instance, while the Green Paper generally does not endorse particular policies, only sets out issues and options, yet we read in the Irish Times that the promotion of oil and gas exploration and the development of a regulatory framework for such activity have been identified as priorities for new Minister for the Department of Communications, Energy and Natural Resources (DCENR) Alex White in briefing documents prepared by the Department. Was this position adopted before the Green Paper public consultation concluded? The timing certainly suggests so. If so, it appears senior staff in the DCENR already have committed to a policy of expansive exploration, extraction and usage of fossil fuels (including natural gas by fracking?). Of course, the Minister and the government do not need to heed this recommendation.

The Core Policy

Underpinning the Green Paper is the core principle that Ireland’s economy must go from one “predominately dependent on imported fossil fuels to a more indigenous, low-carbon economy based on renewable energy, energy efficiency and smart networks.” At 8, Summary.

We do need to parse this sentence since it is central to the policy under development. While there is a clear need to reduce, even eliminate the importing of fossil fuels, the overriding goal, required by climate change, must be to reduce and eliminate the usage of all fossil fuels. Replacing imported fossil fuels with home-grown fossil fuels, for instance in the form of shale gas extracted by hydraulic fracturing, or fracking, is not a step forward but just more reliance on fossils fuels. As the Irish Environmental Pillar argues in its submission, “A moratorium on fossil fuel exploration should be instigated, in line with the recommendations contained within the recent IPCC reports, which explain that to prevent runaway climate change globally over 60% of fossil fuels need to remain in the ground.” At 2.

Renewable Energy World

Whether to permit fracking, is not only an environmental regulatory problem but also an energy issue. The environmental review of fracking that is being undertaken by EPA, and the NI agency, can only be part of the analysis of whether to allow fracking. The other consideration must be whether it makes sense as an energy and climate change policy.

Given the intense opposition to fracking on the island, and the determination to proceed with fracking by the UK government, and part of the NI government, you would think there would have been a discussion of the possibilities and limitations of fracking and whether fracking fits in with the other components of a sensible, comprehensive energy policy. Yet the phrase “hydraulic fracturing” appears only in passing in the government’s Green Paper, in reference to the EPA study. At 46.

It is not a persuasive argument that the Department cannot assess the pros and cons of fracking until the EPA study is done. It is not only not persuasive, it is not logical. Whatever are the adverse environmental and health impacts from fracking, and whatever are the regulatory controls and oversight that EPA determines would be necessary if fracking were approved, those considerations may be irrelevant to whether fracking makes sense as an energy and climate change policy, for the reasons suggested above. At least the report should have raised the various dimensions to the consideration of fracking, without having to take a position on it.

In addition, renewable energy, including wind, is a cornerstone for the unfolding energy policy, yet Ireland has been less than successful in convincing communities of the critical need for wind energy. In its Green Paper, the Department mentions in passing that there is a need to build societal acceptance for renewable energy projects, but it is noticeably silent about how and why community opposition to wind farms has deepened (perhaps some failures on the part of government?), and what can be done to address this opposition. The submissions from various environmental Non Government Organisations (eNGOs) are more vocal about this problem and ways to address it.

The Government’s Submission in the Green Paper

Since the government’s last White Paper on energy, in 2007, Ireland continues to rely predominately on imported oil and gas, and energy prices continue to rise, up 29% since 2007, in comparison with a 20% rise in OECD countries. With the economic contraction of 7.3%, the energy demand has fallen by 19% so some energy policies are making an impact on decoupling economic activity and energy use.

All the while fossil fuels, whether home grown or imported, continue to have wide-spread and serious adverse environmental impacts.

Also since 2007, Ireland has entered into a Single Electricity Market (SEM) with Northern Ireland, and participated in the interconnector linking Ireland with the United Kingdom and European energy markets. Each has opened possibilities for energy development on the island.

While Ireland is on track to meet its 2020 renewable energy obligations under EU commitments, the 2030 targets will be challenging to meet.

The Green Paper organizes itself through six policy priority areas, and offers up a series of questions under each area to stimulate further discussion.

(1) Empowering Energy Citizens: focuses on how to inform citizens of choices and technologies, especially smart meters, ways to reduce costs and emissions, and new relations with energy suppliers. It also raises issue of what energy impact assessments are needed for energy decisions, and what should be the form of “public consultation.” Unfortunately, as pointed out above, nowhere in this discussion is there any mention of windfarms or fracking or grid pylons, the most contentious “energy citizen” issues on the island.

(2) Markets and Regulation: calls for enhanced connectors and integration of energy system, especially in preparation for the European Internal Energy Market in 2016, and asks for submissions on what regulations are necessary to address competition between energy suppliers, especially in the context of the developing EU internal market.

(3) Planning and Implementing Essential Energy Infrastructure: discusses the integration of renewable electricity with the grid and ways of meeting energy demands, as well as how to improve planning and licensing process for energy infrastructure for stakeholders, presumably including affected communities, and developers.

(4) Ensuring a Balanced and Secure Energy Mix: focuses on optimizing indigenous natural resources and energy storage, including in collaboration with Northern Ireland and UK, and raises questions about viability of coal, biomass and nuclear as well as possible alternative transport fuels and how to incentivise switch to low-carbon heating.

(5) Putting the Energy System on a Sustainable pathway: here it discusses what we referred to above as the core principle, and includes discussion on importance of better energy efficiency, and how to encourage private investment in energy efficiency, and make sustainable energy measures more predictable and transparent.

(6) Driving Economic Opportunity: argues that energy efficiency and low carbon energy supply is critical to attracting multinational businesses; discusses the need for developing innovation in energy sector, including wind, wave and tidal; and asks what training and skills will be needed for energy systems of future, and what levels of government sponsored research and development is needed.

As a “Green” paper, of course, the government is in effect creating the framework for further discussion and is not offering detailed, concrete plans on how to proceed.

Some Submissions from the Environmental Community

Environmental Pillar

One submission is from the Environmental Pillar, an umbrella organization representing over 25 eNGOs in Ireland in promoting sustainable and other policies to governments on all levels and providing a channel for governments to engage with environmental communities. As fundamental principles underlying any energy policy, the Pillar calls for more ambitious targets than those from the EU; much more engagement with the community; less focus on energy prices (Ireland has no control here) and more on energy costs, which take into account reducing consumption and more efficiency; a taxing mechanism; and, a commitment to phasing out fossil fuels in Ireland.

Such actions are needed in light of the continuing reliance on fossils fuels. As the Pillar submission notes, Ireland has an “increasing dependency on fossil fuels (93%, up from 92% in 2011), an extremely high cost of importing fuels (€6.5 billion in 2012), an increasing reliance on the most polluting fuels (coal and peat used for electricity generation increased by 27% and 16% respectively in 2012), and a subsequent relative decrease in renewable technologies.” At 11.

A robust, concrete and sustainable energy policy is widely supported by the recent (2014) Eurobarometer survey, which found that “82% of Irish people think fighting climate change and using energy more efficiently will boost the economy and jobs, 74% agree that reducing dependence on fossil fuels could benefit the EU economy, and 89% think it is important for our national Government to set targets for renewable energy.”

In light of this wide-spread support, the Pillar takes issue with the Green Paper’s concept of the “energy citizen,” finding it too narrow and not accounting for citizens as generators of energy nor for community or co-op energy projects. Any energy policy has to start with intensive, broad, interactive engagement with the wider public, not just the usual “stakeholders.” The Pillar argues that that engagement should be guided by the Aarhus Convention guidelines on public participation. There is no need to reinvent the wheel that already exists for public participation, or ignore it.

The starting point for further consideration of an energy policy, according to the Pillar, is that “When the market is allowed to make decisions on the energy mix, a safeguard must be in place to ensure that the costs of carbon are included in the cost of the fuel.” At 7. The Pillar then proceeds to offer further specific comments and suggestions for each of the 6 priority areas.

Community Energy Group

Another submission comes from the Community Energy Group, a coalition of some 30 eNGOs, where the emphasis is on the need and requirements for community, or co-op, energy projects. The group defines such projects as those involving citizen and local ownership and participation in renewable energy generation, distribution, and energy efficiency. In such projects, the country’s natural resources are used for direct benefits to local communities. The Group distinguishes local ownership from situations where energy development companies pay money to communities for benefits to compensate (buy off) local communities for energy company private development projects.

The submission makes it clear that co-op energy projects are not limited to wind farms but also encompass solar panels on roofs of local buildings, biomass-fed district heating systems, anaerobic digesters on local farms, and collective insulation projects.

The Group’s basic principle is that there must be a fundamental change in energy policy from “an energy system based on centralized production using fossil fuels,” where citizens are relegated to the role of passive energy consumers, to decentralized generation and distributed energy resources. At 8. Such a shift is particularly appropriate in Ireland because of its wealth of renewable energy resources. And this shift is even more useful as it opens the possibility of developing economic opportunities in rural communities where many of these resources are found.

Whether the central government is comfortable with this level of community participation is almost irrelevant because in Ireland the transition to a low-carbon economy will happen only with widespread local community support for renewable energy. The recent and increasingly structured public resistance to the development of large-scale energy projects, especially wind, are convincing evidence for this proposition.

The Group’s submission focuses on the barriers to development of community energy projects in Ireland, and the needs for: facilitation of access to the national grid for community projects, micro-generators and auto generators (currently too long, too expensive, and too risky, although this is a complaint of any business venture); a fair price for local projects; a dedicated REFIT system for community energy projects, including solar electricity; funding or financial support for start-ups at community projects, since money for feasibility and planning stages is especially scarce; facilitation of community microgrids, including smart grids and development of off grid energy communities; development of a National Community Energy Strategy. This last development, the Strategy, should include, in the Group’s view, specific, hard targets for community-owned projects; development of co-ownership projects, with required percentage of local ownership (in Denmark it is 20% of wind energy projects); and. administrative support for these projects in the form of technical and financial aid. Details for each of these points is provided in the Group’s submission.

Underlying all these issues is the need for full participation by local communities in setting the terms of any energy policy for Ireland or for any local authority.

Transition Ireland & Northern Ireland (TINI)

Another eNGO submission was filed by Transition Ireland & Northern Ireland (TINI), part of the international movement to build community resilience for adapting to the impacts from climate change and natural resource depletion. As noted above, energy policy is a key component of any adaptation.

This submission concentrates on the need for a comprehensive public participation in designing any local, regional, and national energy plan, and the right for the public to invoke the Aarhus convention for such participation. TINI points out that the widespread opposition to individual renewable energy projects, in the absence of a coherent energy plan, will only deepen without the government engaging with the public in substantive and transparent ways. As noted, energy usage and policies underlying usage affect every person in the country.

TINI argues that publishing a Green Paper with vague, broad outlines is not enough, and inviting the public to make written submissions is not how the public learns what is possible and what makes sense. There needs to be proactive exchanges between the government and public. It notes the recent work of the National Economic & Social Council (NESC) on how social support for the transformation of Irish energy, and wind in particular, can be better understood and achieved, with specific recommendations.

Conclusion: A Long Term Perspective

The challenge for the Department, the government, and citizens, is to develop a broad-based coherent energy policy. The fundamental question is: do we exploit all our natural resources, including fossil fuels, to assure a steady, cheap supply of energy (the easy fix), or do we leave some fossil fuels in the ground or oceans (the harder fix).

In answering that question we must assess all the costs associated with each option.

If we use all the fossil fuels at our disposal, energy likely will be cheaper than not using fossil fuels, and the fossil fuel and energy interests will make more money. But someone will pay more. For Ireland is unlikely going to meet its EU obligations for GHG emission targets for 2030. If more fossil fuel is exploited and used, and the Harvest 2020 agricultural policy of the government expands dairy herds, and methane emissions, then either the government reduces emission for other sectors or pays for GHG credits to meet its obligations. The credits will be paid by the taxpayers, so that in effect the average taxpayer would be subsidizing the fossil fuel and agricultural interests. As for reducing GHG emissions from other sectors, what’s left: industry, residential homes, transport. Perhaps the government will adopt a version of a Chinese solution. Instead of limiting families to one child, the government can limit each family in urban areas to one car, and since that probably would not make up for the fossil fuel and agricultural contributions, the government can limit driving that one car to just a couple of days a week, or only between 8am and 6pm. There are lots of options to protect fossil fuel and agricultural interests.

In figuring out how to handle the intense, competing interests of energy policies, the Department might consider the model presented by the EU Directive on waste management. In that Directive, there is a legally binding obligation to use the least adverse form of dealing with waste as embodied in the following waste management hierarchy:

In a similar vein, one could create an energy hierarchy that legally requires the use of the least climate-damaging form of energy before any consideration of a worse form, and only after a stringent demonstration of the need for a more climate-damaging form of energy. For instance, energy efficiency could be at the top (it eliminates need for energy); followed by renewables, in an order to be determined; followed by the fossil fuels, including natural gas, at the bottom, again in some order. Where to put nuclear would be the subject of an intense debate, but probably it would not matter because it is highly unlikely nuclear power, based on its costs and risks, would be acceptable to the people on the island of Ireland.

Sources

Department of Communications Energy and Natural Resources, Green paper on Energy policy in Ireland and Summary of Green Paper on Energy Policy in Ireland    www.dcenr.gov.ie/Energy/Energy+Planning+and+Electricity+Corporate+Division/

Steven Carroll, “White told promotion of oil and gas exploration ‘a priority,’ The Irish Times (16 August 2014).  www.irishtimes.com/news/politics/white-told-promotion-of-oil-and-gas-exploration-a-priority-1.1898638

Environmental Pillar submission to DCENR on the Green Paper on Energy Policy  environmentalpillar.ie/2014/08/01/environmental-pillar-submission-to-dcenr-on-the-green-paper-on-energy-policy/

European Commission, Special Eurobarometer 409: Climate Change [fieldwork Nov-Dec 2013]. ec.europa.eu/clima/citizens/support/docs/report_2014_en.pdf

Community Energy Group Submission to Green Paper Consultation Recommendations on how to make community energy projects a reality in Ireland  www.foe.ie/documents/submission-to-green-paper-consultation_community-energy-policy-position-paper/

Transition Ireland and Northern Ireland (TINI), Green Paper on Energy Policy Submission (July 2014).  api.ning.com/files/J9FGucqSAtFU2ptBZ5pLx1fYqt6cbOLA9jQsk-If7ConPojuLdwXwluSTJf11GFFXnIyvRx24i21frLMoDasnJ1GQbLTWFDD/SubmissionGreenPaperonEnergyJuly2014.pdf

National Economic & Social Council (NESC), Wind Energy in Ireland: Building Community Engagement and Social Support (July 2014).  www.nesc.ie/en/publications/publications/nesc-reports/wind-energy-in-ireland-building-community-engagement-and-social-support/

European Commission, Directive 2008/98/EC on waste (Waste Framework Directive) ec.europa.eu/environment/waste/framework/

“Feed-In Tariff,” iePEDIA section of irish environment (June 2011). www.irishenvironment.com/iepedia/feed-in-tariff/