Download Love Leitrim Response to Green Paper on Energy 2014

Green Paper on Energy on Energy Policy in
Ireland
A Response by Love Leitrim
27th July 2014
Love Leitrim Response to Green Paper
1.
Love Leitrim and our approach to the Green Paper
This document has been produced by a sub-group of members of Love Leitrim, in response
to the Green Paper on Energy. The group has given generously of its time on a voluntary
basis.
While Love Leitrim was formed in response to the threat of unconventional gas exploration
in Ireland, it nevertheless sees itself as making a significant and positive contribution to the
development of the region.
Love Leitrim Vision
Love Leitrim is an ad hoc community group governed by this constitution and
was formed to promote all the positive aspects of our beautiful unique county and its
contribution to the national wealth and heritage.
Love Leitrim supports long-term sustainable, economic development and the
creation of employment, but not at the expense of existing jobs in tourism and farming or
the welfare of future generations. Leitrim is a vibrant creative inclusive and diverse
community. It is a leader in renewable energy, with a sustainable local economy and is a
model of good practice for Ireland and beyond that can be expanded further to contribute
to the nation’s well-being. The environment in Leitrim is sustainable and safe, with a
beautiful and unspoilt landscape, clean water air and soil and protected flora and fauna.
Leitrim is also an ideal place to raise a family. Love Leitrim will seek to promote and develop
environmentally friendly projects, the importance of recycling, sustainable, and renewable
clean green energy, and its vibrant and artistic community.
Love Leitrim will do everything in its power to oppose what we see as the single
biggest threat to all of these at this present time which is the possible dangers resulting
from hydraulic fracturing, or fracking.
Love Leitrim is fully committed to protecting the environment of Leitrim and
Ireland as well as the health of our children against fracking through an awareness campaign
and non-violent direct action.
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Love Leitrim Response to Green Paper
Contents of this Document
1.
Love Leitrim and our approach to the Green Paper ...................................................... 2
Love Leitrim Vision ......................................................................................................... 2
2.
Love Leitrim Response ................................................................................................... 4
3.
Vision espoused in the Green Paper .............................................................................. 6
4.
Climate Change .............................................................................................................. 7
5.
Energy Mix...................................................................................................................... 9
False assumptions about oil/gas availability.................................................................. 9
Contradictory objectives .............................................................................................. 10
Questions and answers: ............................................................................................... 10
6.
Sustainability ................................................................................................................ 13
7.
Energy Policy impacts on Public Health ....................................................................... 15
8.
Community as a Real Energy Stakeholder ................................................................... 17
Empowering citizens .................................................................................................... 17
People and Process: Cross-Government Collaboration ............................................... 17
Consultation & Aarhus ................................................................................................. 18
What are Real Energy Stakeholders – the cooperative movement............................. 18
Some examples in other countries .............................................................................. 19
What is needed ............................................................................................................ 19
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Love Leitrim Response to Green Paper
2.
Love Leitrim Response
What is a green paper?
A green paper is normally a tentative government report and a consultation
document containing policy proposals for debate and discussion. A green paper does not
give any commitment to action but it is usually the first step in changing the law. Green
papers are intended to stimulate debate and launch a process of consultation, at national
level, on a particular topic. A green paper usually presents a range of ideas and is meant to
invite interested individuals or organizations to contribute views and information; it should
detail specific issues, and then point out possible courses of action in terms of policy and
legislation. It may be followed by a white paper, an official set of proposals that is used as a
vehicle for their development into law.
Ireland is currently facing one of the greatest challenges since the founding of
the state in relation to energy use and climate change. As a developed first world nation we
also have a moral obligation to be a leader in the transition to a low carbon economy and to
ensure that the burden of the effects of climate change does not fall on nations that did not
contribute to the problem of climate change and can least afford it. We have been told by
scientists, environmentalists and world leaders that to continue with ‘business as usual’ is
not an option. We are also in the fortunate position of having abundant renewable energy
potential and therefore are perfectly placed to be a world leader in the development of a
new low carbon economy.
Given the purpose of a green paper and the very significant challenges outlined
above citizens have a legitimate expectation that this document would provide an
overarching vision of how Irelands energy consumers, every single citizen in the state, are to
be protected and provided with the energy required for a functioning economy in a manner
that will also tackle climate change and maintain a safe planet to live on. Unfortunately, as
citizens, we have been abandoned by DCENR, we have been given no vision, no innovative
policies, no leadership and no idea of how Ireland is going to progress to the low carbon
future that is essential for the future. Instead we have been given an industry focused
document that belittles citizens who DCENR see as having no role other than as consumers.
The Green Paper gives us the current position in relation to energy use, reads like a party
political broadcast in regarding their ‘achievements’; mentions commitments to reduction
of energy use in the future with no vision of how they are to be achieved and provides for
tinkering around the edges of current energy policies. In short DCENR’s vision is ‘Business as
usual
If Love Leitrim’s response to this Green Paper appears somewhat disjointed that
is because the Green Paper itself is so poor, we have tried to identify some of the main
issues and to respond to them, we have also highlighted issues that are causing serious
public concern but that have not been dealt with by the Green Paper. We feel that this
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Love Leitrim Response to Green Paper
Green Paper should be rejected by the public and that DCENR should be obliged to provide
us with a Green Paper that provides citizens with clear vision and supporting policies that
will allow a purposeful debate on our energy future.
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Love Leitrim Response to Green Paper
3.
Vision espoused in the Green Paper
The opening sentences of this Green Paper place economy before society and business
before households – it could not be clearer that the focus here is on industry before people.
No vision for the generation, procurement or transmission of energy, for the long term
benefit of the people or the environment, is articulated. The tone of the paper is set –
capitalism, if not outright neo-liberalism, is the hegemonic norm with which we are
expected to unquestioningly agree.
Contrast this with the Danish Government’s strategy ‘Independent from fossil fuels by 2050’
http://denmark.dk/en/green-living/strategies-and-policies/independent-from-fossil-fuelsby-2050/ which opens with this statement – “It is the Danish government’s clear opinion
that the green road is the one we all need to travel eventually.”
Good governance principles advocate clarifying the common values among all stakeholders
when developing strategy. This is on the basis that stakeholders are more likely to engage
with a process, when they can associate an underpinning value to the work of the entity.
There are no values identified here, this may be purposeful or not. From our own
experience, clarifying values - and creating mission and vision statements, allow
development to proceed efficiently and effectively and most importantly, this creates the
basis for future accountability regarding the success of the project. Again the omission of
this exercise from this paper may be purposeful or not.
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Love Leitrim Response to Green Paper
4.
Climate Change
“Climate change is recognised as the most serious and threatening global environmental
problem”. (Page 61 of Green Paper)
While the Green Paper has identified Climate Change as a critical issue, it appears to ignore
this in some of its recommendations.
The rate at which methane leaks is absolutely crucial to the greenhouse gas implications of
the unconventional gas industry. It is sometimes claimed that because natural gas, when
burned, gives rise to less CO2 than the combustion of coal, that natural gas is a climate
friendlier and this is an argument often put forward by the industry to promote the
production of shale gas. The argument neglects the following however - firstly methane is a
much more powerful greenhouse gas than CO2 (100 times worse over a 20 year time span)
so the existence of fugitive emissions from leaking gas wells and pipelines may make it more
greenhouse damaging than coal depending on the rate of leakage. Estimates of typical rates
of leakage and the effects vary - according to the US Environmental Protection Agency the
average rate of leakage is about 2.4% per annum. Many experts believe it is much more
than this. For example, Howarth, Santoro and Ingraffea of Cornell University estimate it at
8% pa (Howarth, Santoro, & Ingraffea, 2011) Tom Wigley found that unless leakage rates
could be kept below 2% substituting gas for coal is not an effective way of reducing
greenhouse gas emissions.
(Wigley, October 2011, Vol 108 (3))
A crucial finding here is that measurements of leakage from gas installations, the so called
“inventory measures” are much smaller than findings taken by flying planes over gas fields.
“NOAA researchers found in 2012 that natural-gas producers in the Denver area “are losing
about 4% of their gas to the atmosphere — not including additional losses in the pipeline
and distribution system.” Another 2013 study 19 researchers led by the NOAA concluded
“measurements show that on one February day in the Uinta Basin, the natural gas field
leaked 6 to 12 percent of the methane produced, on average, on February days.” The Uinta
Basin is of special interest because it “produces about 1 percent of total U.S. natural gas”
and fracking has increased there over the past decade.”
(Sweeney & et al, 2013)
In response to these studies defenders of the oil and gas industry have challenged the
higher leakage rates with a study of their own produced by academics at the University of
Texas. This study claims a very low figure of 0.42% leakage of gross annual natural gas
production. (Allen et al., 2013)
Other academics have cried "foul" on that study since the gas industry self-selected whether
they wanted to be in it or not – so it is to be expected that it was the companies and sites
that have a low leakage that were prepared to come forward in what is also a very small
sample. The Texas study has also been criticised because it does not mention gas leakage in
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Love Leitrim Response to Green Paper
infrastructures. Nor do the authors discuss the discrepancy between their findings and
those of the researchers who took field measurements. (Shonkoff, 2013)
Secondly, even if it were the case that gas was more climate friendly than coal it would only
be helpful in reducing greenhouse gas emissions sufficiently if gas actually replaced coal and
is not used additionally to coal. In the USA increased natural gas production has led to some
coal being exported instead of being used domestically - a part of this has been to the UK
where low coal prices have led to UK power generators using more coal. The carbon
intensity of UK power generation rose in 2013 because of this.
Thirdly, to avert a climate catastrophe the International Panel on Climate Change is arguing
for a carbon budget to prevent global temperature rises overshooting a 2 degree increase.
This means effectively a 6% per annum reduction in emissions for the next few decades. For
this speed to be achieved it is not only necessary to radically reduce energy use but to
transform the energy system directly over to renewables not to go through some
intermediate process via an allegedly slightly more benign fossil fuel. According to research
led by the Grantham Research Institute (under the leadership of Lord Nicholas Stern )
"Between 60-80% of coal, oil and gas reserves of publicly listed companies are already
‘unburnable’ if the world is to have a chance of not exceeding global warming of 2°C".
(Carbon
Tracker
Initiative
and
Grantham
Research
Institute,
2013)
The above extract was written by Brian Davey (2013)
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Love Leitrim Response to Green Paper
5.
Energy Mix
The general context in which this green paper is written can be summarised as follows:
1.
2.
3.
4.
a growing economy is essential to society
the economy can continue to grow
the energy required to grow the economy is accessible and affordable
our climate change targets are sufficient manage the impact of climate change
This is a "business-as-usual" approach that ignores the climate impact of continued use of
fossil fuels - in the 2012 World Energy Outlook, the IEA wrote in the executive summary "No
more than one-third of proven reserves of fossil fuels can be consumed prior to 2050 if the
world is to achieve the 2 °C goal”, the internationally recognized limit to average global
warming in order to prevent catastrophic climate change. In other words, over two-thirds of
today’s proven reserves of fossil fuels need to still be in the ground in 2050 in order to
prevent catastrophic levels of climate change.
False assumptions about oil/gas availability
The modelled scenario in figure 6 is based on the assumption that Ireland meets our current
RES and efficiency targets. But what is ignored is that, over the time period to 2020, the
total amount of energy available to the world economy from oil and gas production will
almost certainly peak. There is a general consensus between industry leaders and analysts
that world oil production will peak between 2010 and 2030, with a significant chance that
the peak will occur before 2020. [ Madureira, Nuno Luis (2014). Key Concepts in Energy.
London: Springer International Publishing. pp. 125–6. doi:10.1007/978-3-319-04978-6_6.
ISBN 978-3-319-04977-9.][Sorrell, Steve; Miller, Richard; Bentley, Roger; Speirs, Jamie
(September 2010). "Oil futures: A comparison of global supply forecasts". Energy Policy 38
(9): 4990–5003. doi:10.1016/j.enpol.2010.04.020]
When discussing the appropriate energy mix, the approach seems to be to lower it as much
as possible without undermining the economy, but several other factors need to be taken
into account:



the climate change impact on the economy of this mix
the climate change impact on the production and distribution networks predicted by this
green paper
the best available information of the like availability and cost of oil/gas over the period
in question
It is misleading to imply that the amount of oil/gas used in Ireland is curtailed only by the
amount of energy we can get from RES and increased efficiency. The paper predicts our
energy needs between 2015-2020 is about 83Mtoe, of which 67Mtoe will come from oil,
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Love Leitrim Response to Green Paper
coal, or gas. The paper simply does not address the question whether it will be possible to
get energy at affordable prices from these sources over that period.
The government should be preparing for a situation where 67Mtoe simply cannot be
sourced or afforded.
Contradictory objectives
The paper states that Government’s underlying objective in respect of oil and gas
exploration is to ensure that the State’s natural resources are managed in a way that will
maximise the benefits accruing to the people of Ireland. It is disappointing and worrying
that "benefits" seems to be thought of only in terms of jobs and the economy, and that
impact the State's natural resources on public health is not even mentioned, let alone
prioritised.
Another worrying statement regarding oil/gas exploration is "It is a central tenet of the
State’s strategy for this sector that private industry rather than the Exchequer is best placed
to assume the high exploration investment cost and high financial risks associated with
offshore exploration." The private sector will only take on this risk if the government is
permissive in allowing the private sector to commercialise anything it finds - and there will
be no chance for public participation or protection of public health and the public benefit.
There is a fundamental contradiction between the Government's "underlying objective"
regarding maximising the benefits to the people of Ireland, with the "central tenet" of
letting private industry bear the financial risks of exploration.
It is also critical that the "robust regulatory processes" are established to protect the public
interest and public health, and that they are properly resourced by the exchequer - the
money the government thinks it can save by allowing private industry to bear the cost of
exploration will need to be spent on regulating industry if it wants commercialise its finds.
Regarding unconventional hydrocarbon resources onshore, the green paper says "No
decision will be made on proposals for the use of hydraulic fracturing in unconventional gas
exploration until the results of this EPA research, which is projected to conclude in the
second quarter of 2016, have been considered." It is worrying, and one could infer bad faith
by the government, that this green paper should be proposing policy objectives and targets
that assume the production of onshore gas from unconventional sources.
Questions and answers:
24. How best should we ensure that appropriate framework conditions are in place for
secure markets and infrastructure with sufficient capacity and investment in the medium to
long term?
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Love Leitrim Response to Green Paper
Greater emphasis should be placed on local energy generation and distribution. The
emphasis on global-scale generation and distribution of energy is inherently unsustainable in
the medium and long term.
Irish businesses should now pay more attention to minimising their energy costs than to
cutting their wages bill. This could mean reskilling their workforces, paying them more and
using less capital equipment. It could also mean using longer-life buildings and machinery
and holding larger stocks – in other words, increasing their use of capital.
The government should revise its spatial strategy to take into account the different transport
patterns associated with tight energy markets.
There should be a much greater emphasis on renewables than even the green paper
envisages, since countries or communities able to offer secure energy supplies at fixed prices
will have a big competitive advantage.
25. How can we optimise the policy and regulatory environment to enable the market to
decide on an appropriate fuel mix from a grid, market design, carbon, cost and energy
security perspective? Are current policy and regulatory instruments sufficient or are
additional interventions required, and what should those be?
The government should not rely on the market to allocate increasingly scarce and expensive
energy resources among competitive buyers. This approach will lead to using interest rates
to control the inflationary pressure of rising energy costs, which will impede investment in
RES.
Regulatory responses are not sufficient to protect the public interest, either in their
substance or in their resourcing. Responses should be more invasive and independent than
those currently under consideration.
At an international level, governments should ration the available energy supply so that the
prices paid to producers are controlled. The world’s central banks should allow a controlled
inflation so that the effects of the higher oil prices can be passed through to consumers and
reflected in a new relative price structure. However, as every citizen gets a tradable energy
allowance, they get an income when they sell their allowance which protects them from the
worst effects of the inflation.
26. Given that Moneypoint will approach the end of its life by 2025, is there a role for coal in
the future power-generation fuel mix, taking into account cost, security of supply and
environmental issues? If coal generation does not continue at Moneypoint, what are the
alternatives? Should options such as biomass or nuclear power be considered?
There is no role for coal in the future power-generation fuel mix, given that a) it is a finite
resource that can never be sustainable b) that it is detrimental to mitigating climate change
and c) investments in it will only divert investments from sustainable alternatives.
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Love Leitrim Response to Green Paper
Alternatives include developing products and markets for long-life and repairability, so that
the benefit of energy use can persist longer in the economy. Fourth-generation nuclear
technology should be studied further. Self-sufficiency in energy should be an explicit policy
goal.
27. What strategy is needed to support the continued increase of renewable energy on the
electricity grid? Are new approaches needed?
No efforts should be made to keep energy cheap. Price stability and predictability is more
important. The sooner investments of energy capital are made in saving energy and in the
transition to renewable energy, the more substantial those investments can be and, as a
result, the smaller will be the extent to which the economy contracts as the imported energy
supply tightens. Foregoing economic growth now for the sake of achieving greater energy
self-sufficiency will enable the country to maintain higher incomes in future.
The main national goal, the generation of economic growth, should be abandoned in
favour of maximising the rate at which renewable energy sources are developed and
energy use is reduced.
Once it has become clear that the peak in oil production has been reached, the distribution
of what will become an increasingly scarce resource cannot be left entirely to the market as
that would lead to a widening gap between rich and poor. Some form of energy or emissions
rationing should be introduced internationally
Research should be commissioned in renewable energy areas in which Ireland could acquire
a first-mover advantage for its energy producers or equipment manufacturers in the way
Denmark did for its farm equipment makers who moved into wind turbine production and
went on to gain 60% of the world market. Suitable research areas include:
 tidal flow, wave, and deepwater offshore wind,
 second generation biomass refining processes,
 electricity storage technologies including compressed air, flow batteries and
flywheels
 distributed generation
 sequestering carbon in agricultural soils
 producing, cleaning and compressing biogas for motor vehicle use
 the development of smart heating systems and appliances that can be programmed
to operate well on intermittent electricity supplies
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Love Leitrim Response to Green Paper
6.
Sustainability
The government is right to put sustainability at the centre of its energy green paper.
However, it's impossible to say just what they mean by sustainability. The green paper
mentions the word over 50 times, and yet it is not explicitly defined. If we are to take its
ordinary meaning "able to be maintained at a certain level", then the paper uses the term
incorrectly and misleadingly. Anything can be maintained at a certain level, if you track that
level over a small enough time periods. The Celtic Tiger was certainly "sustainable", or
seemed that way, and the great and good asserted as much back in 2006 - until it wasn't. A
bit like the man falling from a tall building, who after falling passed each floor on the way to
the ground said to himself "so far so good".
The point is that there is nothing in the green paper that can be defended on the grounds of
"sustainability" - the green paper bandies the term about saying that "putting the Irish
economy on a sustainable growth path is at the heart of policy", that "reliable, sustainable,
affordable energy is vital to Ireland's economic success", that "a stable regulatory
framework is critical to achieving competitive, secure and sustainable energy outcomes".
Judging by context, it would seem that "sustainable" means "able to meet predicted growth
in energy demand until about 2030-2050". And then what? Given that most of the sources
of energy that the green paper imagines will provide us with the bulk of our energy are
based on finite and vanishing resources, how "sustainable" is it if at the end of the period
our energy systems collapse because we've run out of raw material. Well, it was sustainable
while it lasted.
At the recent energy Ireland conference at Croke Park, Prof Michael Bradshaw put the
question quite simply: Can we have secure, affordable and equitable energy services that
are environmentally benign? I would add to that "that can be sustained for at least 3
generations - the last descents to have direct contact with people living today".
What if sustainability can only come at the expense of security (i.e. we have to put up with
regular outages)? If we keep security, maybe we have to give up affordability (i.e., only rich
people can have a secure supply)? If we keep security and affordability, maybe we have to
give up equitability (i.e., the energy resources of some are exploited for the benefit of
others)?
The paper assumes that a) global demand for energy will continue to be met globally
(through efficient generation and distribution networks) that b) energy production will
always be a centralised, energy intensive activity and c) the desirability of increasing
production and standards of living is axiomatic.
To emphasis the green paper's complacency and uncritical acceptance of the current ways
we produce and consume energy, one could do a lot worse than look at "Envisioning a
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Love Leitrim Response to Green Paper
Sustainable Ireland from an Energy Availability Perspective", a 2007 report produced by The
Foundation for the Economics of Sustainability for the EPA. It observed that, in a world
where energy costs will continue to rise, in absolute terms and relative to the cost of labour,
the pattern of production and distribution has to change - with a move toward producing
and consuming energy locally, a return to co-operative, community-based bioprocessing. A
world powered by large generation centres, connected by global networks of pipelines,
roads and cables will come to an end - as will shopping-as-a-pastime, and tourism.
Perhaps the Brahmins in the department of energy considered these conclusions and had
alternative research to discount them as nothing more than chicken-little. Or maybe the
implications of it are simply too radical to take on.
One way to look at it is to say that if sustainability is at the centre of the green paper on
energy...then the green paper is a doughnut.
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Love Leitrim Response to Green Paper
7.
Energy Policy impacts on Public Health
The health and wellbeing of an individual or a community is determined by several
interacting factors. These factors include: material circumstances, the physical and social
environment, psychosocial factors, behaviours and biological factors.
In turn, these factors are influenced by social position; itself shaped by education,
occupation, income, gender, early childhood development, ethnicity and race. All these
influences are affected by the socio-political, cultural, social and environmental contexts in
which they sit.
General socio-economic, cultural, social and environmental conditions encompass;
Agriculture and food production, Education, Work environment, Living and working
conditions, Unemployment, Water and sanitation, Health care services, Housing, Social and
political environment, Governmental strategies and Policies, Social service provision, Social
Networks, Political Stability, Availability of essential services and Social Status.
Energy Policy, which has the potential to influence several, if not all of the above factors,
cannot be separated from the preservation of public health. In fact Energy Policy can be
seen as an opportunity to protect public health.
Health is mentioned exactly twice in this document. This is a glaring omission on the part of
the Minister.
The first mention is on page 22 – “Inability to afford adequate home heating or lighting is
detrimental to health and wellbeing.” Poverty is detrimental to health and wellbeing.
Tinkering around the edges of a person’s inability ‘to afford adequate home heating or
lighting’ does little or nothing to address the cause of that poverty and its subsequent
effects on health and wellbeing.
The second mention is on Page 71, where the Minister predicts that
“In the coming years, the energy sector will become more central to the Irish economy and
more Government Departments, such as Agriculture, Health and Social Protection, will be
affected and can be expected to become more engaged in energy policy decision-making.”
It is difficult to know what the Minister means here. How will the Department of Health be
affected in the coming years? Is it that the Department of Health may become involved
when a response is required to mitigate the ill-effects of an energy policy, which did not
take health into account? Does the Minister see no role in energy policy formulation, for the
large section of the Department of Health dedicated to safeguarding Public Health?
The participation, from the outset, in energy policy formulation, of Public Health experts
(this is not the same as, and cannot be substituted for, by Environmental Health, Minister) is
essential.
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Love Leitrim Response to Green Paper
This is in order that; the precautionary principle can be built in to any proposed policy, an
understanding that ‘low-risk’ does not mean ‘safe’ can be shared with other policy makers
and, the knowledge that mitigation of health effects by regulation does not work, can be
clearly disseminated when drawing up the policy.
With specific regard to unconventional shale gas exploration and extraction, in July 2014,
Concerned Heath Professionals of New York published a Compendium of Scientific, Medical,
and Media Findings Demonstrating Risks and Harms of Fracking. For some time, the industry
had exploited the newness of this method of fracking to deflect any questions about the
health impact, on the grounds that there is no supporting evidence.
This compendium extensively documents significant and numerous impacts under ask of the
following headings:
1.
Air pollution
2.
Water contamination
3.
Inherent engineering problems that worsen with time
4.
Radioactive releases
5.
Occupational health and safety hazards
6.
Noise pollution, light pollution and stress
7.
Earthquakes and seismic activity
8.
Abandoned and active oil and natural gas wells (as pathways for gas and fluid
migration)
9.
Flood risks
10.
Threats to agriculture and soil quality
It's about time the government takes this evidence seriously, replacing the current
patronising attitude with a recognition that fracking will be damaging to public health and
destabilizing to society. Avoiding these outcomes is one of the most fundamental roles of
any government - though the government seems to think that cuddling big business is its
first and only priority.
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Love Leitrim Response to Green Paper
8.
Community as a Real Energy Stakeholder
Empowering citizens
With the clear primary focus on supporting the existing (fossil-fuel-based) energy industry,
rather than the people, or the environment, or the serious development of renewable
energy sources - the discussion on empowering energy citizens becomes puzzling. What is
an energy citizen? The Minister does not give any definition for this term.
The term ‘empowered energy citizen’ brings to mind, on the one hand, a citizen who has
choices, who is involved in the decision making process and who has power. But perhaps, on
the other hand, and energy citizen is simply an energy consumer? A very different
construction!
People and Process: Cross-Government Collaboration
The minister proposes "to establish an informal ad-hoc group that would meet from time to
time to consider, and seek to resolve, issues that may be preventing energy related
projects that could give rise to investment and employment. Government Departments (e.g.
the Department of Communications, Energy and Natural Resources, Department of the
Environment, Community and Local Government and the Department of Jobs, Enterprise and
Innovation) and agencies (e.g. Industrial Authority of Ireland, Enterprise Ireland, Forfás,
Sustainable Energy Authority of Ireland and the Commission for Energy Regulation) will seek
to be as flexible and adaptable as possible, while respecting the regulatory and statutory
remits of all bodies, in their pursuit of solutions to remove barriers to investment. The
Department of Communications, Energy and Natural Resources proposes that the ad-hoc
group of civil and public servants would work collaboratively to overcome obstacles and
explore new opportunities in the energy sector. The group will be guided by two key
principles: (i) a spirit of flexibility and adaptability, and (ii) the need to execute, maintain
momentum and progress.” (Page 70)
This section must be read in the full knowledge of what happened in 2005 in the US, where
“The federal Energy Policy Act of 2005 contained a provision that has come to be known as
the "Halliburton Loophole," an exemption for gas drilling and extraction from requirements
in the underground injection control (UIC) program of the Safe Drinking Water Act (SDWA).
Other exemptions are also present in the Clean Air Act and Clean Water Act.”
(http://cleanwater.org/page/fracking-laws-and-loopholes). And in recognition of the current
The Transatlantic Trade and Investment Partnership (TTIP) negotiations which pose a very
real threat to all the hard-won battles that have been fought to create and maintain
standards and regulations that hold industry to account. Citizens need to have a place in this
ad-hoc group.
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Love Leitrim Response to Green Paper
Consultation & Aarhus
The consultation approach proposed by the Minister needs to comply with the Aarhus
Convention, which lays down a set of basic rules to promote the involvement of citizens in
environmental matters and improve enforcement of environmental law. The provisions of
the Aarhus Convention are broken down into three pillars:
1.
access to information,
2.
public participation in decision making and
3.
access to justice
Furthermore, Directive 2003/4/ec of the European Parliament and of the Council on public
access to environmental information is the legislative text which;
a)
guarantees the right of access to environmental information held by or for public
authorities and to set out the basic terms and conditions of, and practical arrangements for,
its exercise; and
b)
ensures that, as a matter of course, environmental information is progressively
made available and disseminated to the public in order to achieve the widest possible
systematic availability and dissemination to the public of environmental information.
What are Real Energy Stakeholders – the cooperative movement
Although the Green Paper mentions the community in several places, it is typically either in
the context of a consumer of energy, or as a stakeholder in accepting the overall needs of
energy providers or the transmission system. These roles are of course vital to the future of
energy in Ireland, however they fall very far short of the visionary strategy to proactively
facilitate the involvement and participation of the community as a key partner in energy
policy development, energy generation, distribution and consumption. This will be even
more important when current levels of economic growth (albeit low) are no longer possible
or feasible, and renewable energy generation locally becomes a prerogative, due to the
impending pressures from climate.
The Green Paper emphasises a market-driven, essentially centralised energy production
system, without exploring other alternatives, and specifically no mention whatsoever of
energy cooperatives. It also fails to address the significant body of opinion worldwide, which
seeks to find an alternative to the growth economy. One of the possible answers to these
issues lies in the cooperative movement when applied to energy.
A specific model, which could be unique to Ireland but learning from best practice
elsewhere, needs an explicit strategy and support from central Government.
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Love Leitrim Response to Green Paper
Some examples in other countries
These cooperatives essentially look to their members for increasing investment activities.
Denmark has over 100 wind turbine cooperatives which own three-quarters of the country’s
turbines, and the country is well on its way to achieving the Government target for 100%
renewable energy (electricity, heat & transport) by 2050.
In Germany, 942 energy cooperatives were officially registered by the end of 2013, with
more than 800 of these having a primary focus on renewable. These are typically small to
medium sized organisations, which provide local employment and decentralised energy
production and distribution. There has been very significant growth in such organisations in
the past 10 years.
In both countries over half the renewable energy generation is community owned, with the
coops enabling enhanced citizen participation.
In Canada, while there are not as many cooperatives proportionately - perhaps influenced
by the energy policies in the USA, there is a greater emphasis on biofuels. It is also
noteworthy that cooperatives flourish where there is a favourable policy environment, price
clarity and recognition of the importance of the community as a stakeholder (for example
Ontario), whereas the development has been less in other areas, where such polices do not
exist.
These examples show what could be done in Ireland, where we have a more favourable
wind regime, and also with significant untapped potential for energy from biofuels and
forestry.
The involvement of communities in these countries in energy generation has led to a deeper
understanding by citizens of the issues involved - contrast recent and current practice in
Ireland – Transmission line controversies, fracking protests, Corrib etc.
While the NESC report recommends in part community ownership, it deserves more
emphasis.
What is needed
A Specific Community Energy Strategy
The Strategy would for example:

Identify the barriers to the development of a community based energy approach for
Ireland
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Love Leitrim Response to Green Paper

Integrate successful concepts used in other countries, including profit and non-profit
based systems, local and regional approaches/structures etc.

Identify current initiatives and projects in Ireland that might enhance the approach
or benefit from it, e.g., smart grid, e-cars, Comharchumann Fuinnimh Oileáin Árainn,
Westport Energy Cooperative etc.

Develop a supportive and innovative capital funding approach – this might entail the
involvement of State Agencies such as the ESB, Bord Gáis, as well as Credit Unions, Group
Pension Schemes etc.

develop positive, attractive and proactive approaches to grid connection (if needed),
so as to encourage smaller local players to take initiatives

explicitly engage with communities

Set metrics and targets for the short, medium and long term

Develop a communications approach
Development of the Concept for Ireland
While much can be learned from other countries, Ireland has a rich history in the
cooperative movement, and this could be used to develop an approach to allow us to catch
up with other countries. The national Spatial Plan conceptually sought to emphasise a
primary focus on our use of ‘space’. There is a need for a recognised ‘Energy Spatial
Strategy’, based on the future projected needs of regions – rather than local authority based
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