Gluaiseacht Submission on the Micro-generation Support Scheme (MSS)

Gluaiseacht submitted the following to the consultation on Micro-generation Support Scheme (MSS) in February.

A pdf of the submission can be read here: Gluaiseacht submission on MSS Consultation.pdf

● The climate crisis means we need to urgently reduce greenhouse gas emissions. We
need to transition our energy system away from fossil fuels to a completely renewable
energy system, but more importantly we need to reduce our overall energy demand,
which is a “fossil fuel era” demand.
● We want the energy system to be run for the public good. A system run for profit is
fundamentally incompatible with energy demand reduction.
● We reject the principle that this MSS has to pay for itself - it should be paid out of
general taxation, to lessen the risk of poorer people subsidising wealthier people.
● This MSS should specifically incentivize community projects and not focus solely on
individual homeowners. Collective community energy projects have a greater ability to
bring benefits of renewable energy to the whole community rather than just those owning
their own homes.
● The suggested BER of a C rating or better would currently exclude 45% of the houses
in the country. It violates the principle of "equity" which is supposedly sought after
in the design of the scheme.
● The 6/11kW limit on the size of microgeneration is very low in comparison to
similar schemes in Europe and is needlessly restrictive.
● Participation in this scheme should be clear and straightforward, in contrast with
the Government consultation documents for this scheme.
● Of the policy options available we would suggest the Feed-in-premium or feed-in-tariff,
but not as described in the Ricardo consultants report

1. Introduction
2. An Energy Budget - The Bigger Picture
3. Building Energy Rating
4. Thirty years behind Germany
5. Capacity Banding
6. Choosing technology
7. Choosing policy

Ireland has negligible citizen ownership of renewable energy production thus far.
Despite currently being reported to have the second highest percentage of electricity
provided by wind energy, we have chosen to exclude citizens and communities from
this. In contrast other countries such as Germany (42% of the renewable electricity
generated in Germany in 2016 came from projects carried out by the citizens or with
strong public participation) and Denmark have empowered their citizens to get involved
in renewable energies.
With this in mind, it is first of all worth exploring why this way of working and thinking
about something that would clearly be beneficial to citizens and communities in Ireland
has been ignored for so long and instead a centralised electricity generation system has
been chosen over the last few decades.
Historian Diarmaid Ferriter has written many times about the centralisation of political
power in Ireland. In an article by him in the Irish Times entitled "Why Irish local
government is so useless" he wrote:
“In his provocative observations on local government in the 1980s, historian Joe Lee
caustically noted the glaring gap between the much-vaunted self-reliant community, so
intrinsic in terms of propaganda about the ability of the Irish to run their own affairs, and
the stern realities of the centralising state.
Historically, Lee contended, England had moulded Ireland in its own centralising image
and Ireland had been content to stick with this colonial imposition. Noting that the most
successful European countries operated more decentralised decision-making systems,
and that European regional local authorities accounted for a much higher proportion of
total public expenditure than in Ireland, he remarked, “But decentralisation isn’t good

enough for Ireland. It is scoffed at by the wise men as cumbersome and inefficient.
Why? Partly, of course, as a rationalisation of the natural lust for power ... but
intellectually and emotionally it is because we have conditioned ourselves to think
English.” [1]

If the Irish state is to really enable citizens to get involved in electricity production, it will
have to overcome it's tendency and historical tradition of centralising everything and
help to truly empower communities and citizens.
The fact that Ireland still only has one community owned wind farm is a monument to
this centralising state.
The behaviour of various State agencies should be analysed further to underline this
lack of regard to truly empower citizens in the Energy transition thus far:

SEAI has a long history of being absent in promoting any citizen and community
engagement in electricity generation. It has never promoted Ireland’s only community
owned wind farm Templederry, as a model that other communities should attempt to
emulate. Despite this absence, the SEAI have been recently rewarded by being tasked
with supporting communities through the Renewable Electricity Support Scheme
The SEAI's indifference to community and citizen energy production is in contrast with
its close links with big wind power companies.
It is noteworthy that Brendan Halligan served as Chair of SEAI for 7 years from 2007
until 2014 while at the same time serving as Director of Mainstream Renewable Power.
It is worth noting that Mainstream Renewable Power was just recently sold and was
valued at €1bn. It was totally inappropriate, as evidenced by Mainstream Renewable
Power CEO's letter declaring there was no conflict of interest.[2]
The current Chair of SEAI Dermot Byrne has also previously served as a director in
wind operator Element Power.

Community Power have listed many problems that they have had with ESB & ESBN,
including the extremely long wait for grid connection for community renewable projects,
and even for the processing of applications[3]. This illustrates the conservative nature
and extreme lack of vision that is apparent with the ESB.
The current board of ESB Networks seems to be made up of 3 ESB Executive Staff
along with the CEO of Ireland largest business organisation - Chambers Ireland and the
DG of Engineers Ireland. Where are the people that will advocate for the interest of
citizen or community energy?

An Energy Budget - The Bigger Picture

SEAI have produced a range of future energy scenarios highlighting an absolute
increase in demand 8,9.The increase in demand may increase the levels of
self-consumption rate above the 70% threshold, therefore reducing the amount of
electricity purchased from the grid, thereby further reducing energy spend across
the sectors. As a result, the demand analysis is expected to be conservative in
non-domestic sectors.
- page 18 Public Consultation on a Micro-generation Support Scheme in
Ireland 2021

Measuring current energy usage/demand is a useful stocktaking exercise to see where
we are but we should be cutting our cloth according to our measure.
A better stock taking question is: What electricity production can we reasonably hope to
achieve without sacrificing the landscape, environment and our health to excessive
mega projects? The answer to this would be our energy budget, and we should then try
to match our consumption to stay in budget. Just as a wise minister for finance will try to
balance annual expenditure with annual income, a wise minister of energy should do
something similar. The fossil fuel era is over. Our energy budget will quickly have to be
reduced to our renewable resources.

This would include matching consumption to periods of strong winds or bright sunshine
depending on wind and solar generation fluctuation. A "traffic-light" system with
discounted power available during strong wind/sunshine seems sensible to help
balance demand to supply.
Furthermore demand doesn't just grow by itself in a vacuum. It's subject to government
policy decisions. We need a policy of energy descent that reduces overall energy
demand - not techno-fixes to extract an unreasonable "fossil era" amount of energy
from nominally renewable resources.

Making better use of the existing grid
While renewable energy is favourable to fossil energy, there is no free lunch and
anything can be done badly. All of the hardware for electricity generation and
transmission will involve mining and energy intensive production with its attendant
waste and emissions. In this context it is reasonable to consider the embodied energy
and ecological consequences of expanding the grid to service the continued expansion
of the planned wind mega projects. It is a mistake to follow the fossil fuel model of
generation and distribution for renewables. Fossil fuel occurs in pockets but renewable
energy by its nature is more evenly spread across the surface of the earth. Instead of
massive grid expansion to handle ever more wind mega projects, we should consider
supporting massive well-distributed community home and farm solar PV installations.
This will stress neither the grid nor the receiving communities. It is often said that
smaller distributed installations won’t be as cost effective per kWh as large ones, but
that is without taking into account the massive expense required in grid upgrade to
service the megaprojects, and the immeasurable differences in goodwill and learning.
We have to stop plundering the earth now, even in the name of renewable energy
projects. Let us instead examine how we can use the existing grid and support
microgeneration up to the point the current grid can manage and see where that gets
As a dept of energy spokesperson recently said:
"There is little or no requirement for extra investment in the grid to support
microgeneration. ESB Networks has published a report that assessed the
impacts of increased penetration of micro-generators on their network. They
have concluded that all electricity consumers could install up to 3kW in rural
areas and 4kW in urban areas with little or no impact on the network,"

Taking an average figure of 3.5kW, and multiplying by the number of electricity
consumers in the republic of 1.8 million, means that we could theoretically install 6.3GW
of microgeneration using just the existing grid. This is 150% the national installed wind
capacity of 4.155GW as of the end of 2019, which is the second highest grid penetration
of wind in the world. This is the direction we need to go. The massive grid upgrades that
Eirgrid talk about are necessary mostly for concentrating power and revenue into the
pockets of the wind developers and servicing the data centres.
If this newly microgenerated power is solar, it will be much more valuable than the
equivalent capacity of wind. It will come during the daylight hours, matching demand
well, and more so in the summer, balancing the existing wind resource which is greater
in the winter. When it is very windy at night we already export power. Pushing more
wind projects won’t help security of supply much - when there is no wind there will still
be no wind power. They will just cause more grid upgrades, pylons, increase
community alienation from renewable energy and be felt in everyone’s PSO levy.
Microgenerated solar PV can take a huge bite out of the daily fossil base load. That
should be a primary objective.

Last December a new record was set for electricity demand in Ireland at 5,357MW, in
turn causing an amber warning. If by 2030 some of the predictions of electricity growth
are met (30% increase from data centres, 1 million electric cars & 600,000 heat pumps)
then that figure could easily be doubled, unless large changes of energy usage and
mindset occur. It is most important that the mindset of continuous growth and instant
availability that was allowed to take hold with the growth of fossil fuel usage, isn’t just
transferred to the same mindset under renewable energy. We see that an energy system
that is run for profit is fundamentally incompatible with this need for energy demand reduction.
Building Energy Rating
There is a suggestion in the consultation documents to restrict access to MSS to
houses with a BER rating of C or better. The argument given is "energy efficiency first"
but in practice it will needlessly discriminate against many households. This would
currently exclude 45% of the houses in the country or 64% of the houses built before
2000. It violates the principle of "equity" which is supposedly sought after in the design
of the scheme.
A better option would be to systematically bring houses up to a CER of B or better with
a widespread renovation scheme and change building regulations so that inefficient
homes no longer exist.

As the BER is a calculated measure of average energy use per meter squared of a
building it fails to capture actual use due to individual site specific circumstances such
● User behaviour
● Occupancy
● How well a house is built as opposed to how well it should have been built
Even taking the notional BER values as a reference, a typical 3-bed semi detached
house with a D1 BER rating will cause 5 tonnes of CO2 per year while a typical C2
rated large house will cause 12.7 tonnes - over two and a half times the CO2 rating of
the smaller house. The rating would be sensible if you expect the larger house to on
average house over 2.5 times the number of people, but the reality is that it will on
average house a similar number of people, just with more money or a higher income.
Furthermore the larger building will have taken more energy in materials and
construction. Should the government also penalise for embodied energy of a building in
the MSS scheme?

Figure 1: A guide to BER ratings for homeowners - SEAI

There will be many homes without a BER rating, in particular self-built homes. Some of
these may be energy efficient but difficult to assign a BER rating to due to the use of
natural materials such as straw bale, cob, thatch and sod roofs.
The BER does not account for intelligent architecture such as siting, site aspect,
building orientation, passive heating with thermal mass and good windbreak design
around the house which will reduce heating requirements.

Thirty years behind Germany

"3.3Micro-generation Support Scheme Policy Principles
Micro-generation policy should be based on clear and unambiguous objectives,
and should target specific sectors of society where there are proven market
failures. Despite the potential of micro-generation technologies to help Ireland
meet its energy and emission targets and induce positive shifts in energy
consumption, the rate of adoption among homeowners remains low at
approximately 1.5% of domestic electricity end-users. The reasons include
installation costs, low awareness of micro-generation among homeowners
and homeowners’ willingness to pay (WTP) falling significantly below
market prices."
- page 12 Public Consultation on a Micro-generation Support Scheme in Ireland

Surely the fact that the Irish government is 30 years behind Germany in bringing in an
MSS and so here excess energy is currently given away to the grid is the main reason
for low take up of microgeneration?!

Capacity Banding
"3.6 Capacity banding
The key principles behind the banding of the different technologies used in the
assessment were:
-Alignment with European standard EN50549 “Requirements for generating
plants to be connected in parallel with distribution networks”;
-All connections will be behind the meter, such that any generator installed is to
supply power to a specific load;
-Optimising the micro-generation scheme to support self-consumption with at
least 70% of the electricity being generated used on site.
A 30% limit on the level of export onto the network was chosen to maximise
self-consumption savings, which is the optimal arrangement for prosumers to pay
back their installation costs quickly. Over its lifetime, a micro-generation
installation is a means of reducing energy costs for consumers and will help to
reduce Ireland’s carbon emissions. The scheme also provides limited supports to
incentivise additional installed capacity of renewables where a gap in funding is
not provided by the market, supporting installations across all sectors."
- page 17 Public Consultation on a Micro-generation Support Scheme in Ireland

This is unnecessarily limiting generation capacity because:
If other ill advised thoughts are followed through on half of households may already be
disqualified on BER grounds. Many apartments won't have roof space, many others
won't have the best orientation/shade access etc, and others won't participate for a
variety of reasons. Allow the buildings with good orientation and space install a higher
capacity and recognise the value of the contribution to the grid by paying for it.
Solar in particular matches the national daily demand curve which is higher during
daylight hours. A high solar generating capacity should be encouraged to stabilize the
grid and displace some of the fossil gas/coal base load. Using the grid capacity as a
limit makes more sense, and even then minor upgrades may be justified.

Figure 2: The daily demand curve on Feb 4th 2021 - Eirgrid

Material and installation costs won't be directly proportional to the size of the installation
- allow home generators tailor their system to the site specific conditions rather than an
arbitrary figure.
Is this 30% a limit on balance on instantaneous export vrs consumption? or daily, or
If it is instantaneous, it is totally untenable as much of the generation ( in the case of
solar) will happen at a time of low household consumption during the day while people
are out at school/working, or in the summer while people have less need for heating,
lights or may be on holiday. In the context of locality and the Irish grid however solar
generated power will be very valuable as previously discussed and shown in the Eirgrid
chart above and should be recognised as such.

Choosing technology

The LCOE figures under the base case suggest that the large rooftop and
large ground mounted solar archetypes are the most cost-efficient means of
generating electricity on the microgeneration scale followed by the medium
rooftop and the small and medium ground mounted solar. The small rooftop
solar archetypes are the least cost-efficient among the solar technologies.
- page 24 Ricardo Confidential Report

Yes but they are not taking space up on the ground.
Some people will have appropriate roof space. Some will live in a mountainous area
with a good hydro resource. If the payment is tied to generation then owners will be
incentivized to choose technology wisely and ensure good installation.

Choosing Policy
Grants towards capital costs can introduce more bureaucracy and can encourage
the inflation of hardware prices. However it would be much better to give grants for
microgeneration than for the wind mega projects that also need expensive grid
upgrades as already discussed. The important point would be to pay well for
microgeneration - in particular during peak demand - and allow the site specific
conditions to dictate what technology is installed.
4.2 Feasability
On the other hand, the UK Smart Export Guarantee received the highest
score for feasibility. In this case, the scheme administrator will face some
administration costs although these are expected to be significantly less than
the costs of administering the FITs scheme, given the light touch nature of
the authority’s role, in line with the market based approach of a SEG.
Microgeneration schemes that are based on market-type mechanisms such
as the Northern Ireland example can instead pose significant barriers for

smaller entities to make use of the offerings of the scheme as it increases the
administrative burden; and increases uncertainty regarding return on
investment. In addition, the scheme can also be costly to consumers as all
costs are passed through.
- page 24 Ricardo Confidential Report

Levying the support on the electricity bill SEG style is anti-equity. Poorer people will
be less likely to have the means to invest in microgeneration and so would
experience the scheme by paying more for their electricity. Similarly the rented
generation would just experience it as another rip off. There is already resentment
towards renewable energy projects and their owners/developers due to the PSO
levy. This could become a source of resentment between neighbours if those with
more capital begin to benefit from it at the expense of poorer taxpayers - source the
MSS support from general taxation to avoid this problem.

Mysterious unlabeled table points to SEG. Why?

Figure 3: Misleading chart, page 40 Ricardo Confidential

What does 1 to 5 represent in the above chart? This chart seems to be the reason
for going with SEG policy option.
It seems it represents the criteria listed on page 34:

Figure 4: Selection criteria, page 34 Ricardo Confidential

This comparison between SEG and FIT in the UK is more telling:

Figure 5: Page 37 Ricardo C. report

It would also be feasible, efficient and very applicable to the Irish situation to do nothing
for microgeneration as has been the case for the last 30 years. Should that policy

decision be shown and also get similar high marks to SEG? Effectiveness and equity
are much more important criteria. As shown in the above box, in the UK, FIT delivered
0.9% of the grid's generating capacity per year compared to a projected 0.015% under
SEG. In this Case SEG is projected to get 60 times less capacity installed each
year than FIT did.