The Western Development Commission (WDC) has just made a submission to DCCAE on the Draft National Energy and Climate Plan 2012-2030 (NECP). The development of clear energy and climate action to 2030 is essential to achieving the national goal of a low carbon economy in Ireland by 2050. The WDC recognises that energy and climate action will bring important opportunities for our largely rural region, but at the same time it will bring challenges that we would wish to see addressed in the NECP. The WDC made a detailed submission to the previous consultation on the draft NECP (November 2018), therefore in this submission we only addressed specific issues arising from this draft of relevance to our region and our remit.
The Draft National Energy and Climate Plan (NECP)
The NECP usefully brings together and summarises energy and climate policy. However, much of the focus is on current policy and, while there is a recognition that it will be difficult to meet targets with the policy that is currently in place, there is little information about the additional policies or regulations which will be needed to ensure we achieve targets.
The Plan recognises that heating is a particular issue in rural areas (p4) but there is no specific commitment or policy to address the needs of rural areas either in relation heating or transport. Nor is there a recognition that there are unique opportunities for rural areas from the low carbon economy. We believe that specific rural focused policies could be introduced for this. This would have benefit both in terms of achievement of EU targets and in relation to the development of the rural and regional economies.
Similarly the NECP acknowledges that the dispersed population pattern results in particular challenges in terms of transportation options. Again there is no specific commitment or policy to address the needs of rural areas. The National Policy Framework on Alternative Fuels Infrastructure for Transport in Ireland 2017-2030 notes that it is likely that in future electricity will fuel the majority of passenger cars, commuter rail and taxis while natural gas and biofuels will play an increasingly important role for larger vehicles like HGV and buses. While we would agree with this, we believe that services such as EV charging points and CNG fueling points must be widely available in rural areas where population is dispersed. Without these services being available and reliable, rural dwellers could be reluctant to adopt the new technologies and it could deter visitors who might be concerned about the availability of charging/fueling points. In the case of HGVs and buses, lack of refueling options could increase costs of delivery or services in more rural and peripheral regions.
Electricity transmission network
In relation to the development of the electricity transmission network there is no mention of the issues noted by EirGrid in the recently published Systems Needs Assessment (Nov 2018) in the West (high need for grid development), North West (high need for grid development) and Midland (moderate need for grid development). These need to be included. A study recently commissioned by the WDC, which we blogged about here reviewed the transmission network and current planned renewable generation to identify areas of the Western Region that have transmission capacity for new renewable generation. It found that North Mayo/West Sligo and Co. Donegal have no capacity for new generation without substantial transmission investment. Sligo/Leitrim, South Mayo and West Galway has limited capacity and will require transmission investment in the future. The WDC believes that significant investment is needed in these areas, so that the current and contracted renewable generation requirements are met and that there is potential for further future connections to ensure areas of best resource can produce most.
Gas transmission network
There is a need to review the natural gas network coverage to ensure that it is future proofed to meet the needs of all key urban centres (currently large settlements such as Sligo and Letterkenny are not connected). There is important potential for decarbonisation in the gas network, through the future use of biogas, and through the transmission of gas for CNG refueling. There are also economic benefits for urban centres which are connected to the natural gas network. In the context of the NECP the broader government criteria for developing the transmission network should be reviewed. This should include information from the study of wider benefits of connecting regions to the natural gas which has been undertaken for DCCAE but which has not been published.
We welcomed the target of 500K EVs by 2030 but to help achieve this charging investment needs to be early and widespread. This will not just benefit those living in rural areas but will be important for those for those visiting for business or pleasure. Lack of charging points could in future become a disincentive for visitors and could further concentrate tourism and other economic activities in areas near larger urban centres.
We agree energy efficiency is important and welcome the ambition to increase the number of homes with a BER rating of B and above. However, the most recent BER ratings data from the CSO shows that currently only 15% of homes assessed nationally have a rating of B or above. In the Western Region only 10% achieve this and it is as low as 7% in Roscommon. This highlights the need to specifically address energy efficiency and home heating issues in more rural and less well-off regions. For dwellings in the in lowest rating categories and the costs and difficulties of achieving upgrade to a B rating are most significant.
Most homes in our region use oil for heating. There needs to be a specific effort to encourage change in rural areas which are oil dependent. While many of the incentives are for the installation of heat pumps it should be remembered that the use of wood biomass for heating brings very significant local economic benefits.
Employment is only one factor generating trips and the National Travel Survey shows that majority of travel is associated with non-work trips. The importance of these non-work trips and the potential for change in this demand needs to be more central to climate action planning.
Rural people are reliant on car based transport, they have little available public transport and tend to travel greater distances. Therefore clearly rural dwellers’ transport demand patterns need to be central to planning for climate action. There must be detailed consideration of transport issues for smaller settlements and rural areas. The majority of the population will continue to live in the historical settlement pattern and spatial planning will not change that pattern significantly to 2030 or even in the longer term (to 2050). Thus the NCEP needs to focus on current spatial patterns.
In conclusion, the WDC believes that it is essential that part of the NECP should have a specific focus on issues for rural areas, and on actions to ensure that rural areas are both in a position to benefit from a move to a low carbon economy and to meet the challenges of doing so. This will enable them to make a fair contribution national goals in relation to renewable energy and to actions to mitigate climate change.
Read our full submission here