Clarke Energy - Department of Communications, Energy and

30 July 2014
Energy Policy and Planning Unit,
Department of Communications, Energy and Natural Resources,
29-31 Adelaide Road,
Dublin 2
Re: Green Paper on Energy Policy in Ireland
Dear Sir or Madam:
I am writing on behalf of Clarke Energy in reference to consultation on the
Green Paper on Energy Policy in Ireland.
Clarke Energy is a specialist in the engineering design, installation and
maintenance gas engine based power plants. The company is the largest
distributor and service provider for GE’s Jenbacher gas engines. The
company operates in 16 countries with some 1,000 staff and has over
4,000MW of low carbon and renewable gas-fuelled generation capacity in
its operational areas.
Clarke Energy would like to make the following points for consideration in
relation to this consultation:
Despite the well documented benefits Combined Heat and Power (CHP)
and distributed generation can deliver for Ireland and the environment,
including important carbon and primary energy savings through significant
increases in efficiency, Ireland has one of the lowest levels of CHP
penetration in all of the European Union.
At present the installed and operational capacity of CHP in Ireland stands
at just 284MW, accounting for just under 7% of Irish electricity generation.
This is well short of the 400MW by 2010 target as set out in the
government’s Energy Policy Framework Document 2007 – 2020, published
in 2007. There is also a target of 800MW of CHP installed by 2020 in the
same document.
The fact that Ireland has not met the 2010 milestone of 400MW of CHP
makes the 2020 target of 800MW a much greater challenge and illustrates
the difficult market conditions for CHP in Ireland.
In August 2013 a Roadmap for CHP in Ireland was published following an
intensive consultation process with Irish CHP suppliers, users and policy
makers including SEAI. That roadmap identifies the barriers to the uptake
of CHP in Ireland in detail and makes suggestions how to address those
barriers.
Following the publication of the roadmap, meetings with CHP industry participants tried to
identify a number of messages for the CHP industry to deliver in order to improve the
penetration of CHP in Ireland. Those messages are as follows:
1. A resource in the Department of Communications, Energy and Natural Resources to be
dedicated to the promotion of CHP in Ireland and who will proactively work with the
CHP industry to help develop a CHP friendly environment for the country.
2. Public Service Obligation (PSO) to be levied on a CHP site’s electricity consumption
and not on its Maximum Import Capacity.
3. A full Carbon Tax exemption for all fuel being used in CHP plants in line with other
forms of electricity generation and a simplified mechanism to be put in place for the
recovery of this tax.
4. Feed in tariffs to be implemented for commercial CHP sites that are currently exporting
electricity and getting no compensation for doing so. Tariffs simply to reflect the market
value of generated units of electricity.
5. Government to have a greater understanding of the role CHP can play in helping Ireland
become a more competitive place for industry and in meeting our obligations under the
Energy Efficiency Directive.
Distributed power can improve the fuel efficiency of centralised power plants from the mid
30%s up to 95% when in a CHP configuration, improving energy efficiency; achieve more
sustainable use of Ireland’s import fuel resources and delivering cost savings for end users.
Clarke Energy would like you to consider the above and the CHP Roadmap when formulating
the current revision of the Energy Policy for specifically in relation to CHP in Ireland and are
available to discuss any of the items if further clarification is required.
Comments on other Energy Policy topics:
Primary Energy Efficiency for public buildings:
The new Energy Policy should ensure all energy intensive public buildings (e.g. hospitals) and
facilities are obliged to measure their electrical and thermal energy consumption, implement
energy demand reduction programmes and then address base load primary energy efficiency
by using CHP technology
Biogas:
Current Energy Policy has not delivered on the potential of Biogas for Ireland. Given the
potential of Biogas technologies (e.g. Anaerobic digestion, etc) to deal with agricultural waste
and the biological fraction of industrial, commercial and domestic waste – such “waste” must
be re classified as a national resource and utilised for the production of biogas to convert into
electricity and heat. Biogas used for onsite CHP is a high efficiency renewable energy
technology that is widely adopted elsewhere in Europe. It not only provides renewable
electricity and heat, but also is one of the few types of stable, base-load renewable power.
This compares to wind and solar which only generate power when the wind blows or sun
shines.
Landfill Gas:
Ensure Energy Policy achieves maximum utilisation of all available landfill gas to generate
electricity and thermal energy rather than flaring without benefit.
High Efficiency CHP certification:
Given the relatively low take-up of the High Efficiency CHP certification consideration should
be given to lowering threshold for achieving HE CHP below the current levels to allow more
CHP plants achieve the Carbon Tax rebate thus provide a defacto incentive to improve the
penetration CHP in Ireland.
Energy Consumer Awareness:
Improve energy consumer awareness with the creation of county energy forums and group
energy schemes – to foster greater understanding of “primary energy” verses “delivered
energy” and to improve utilisation of existing energy.
Single Electricity Market (SEM) model:
Ensure Energy Policy achieves greater public engagement with implications of SEM model –
plain language explanations of the drivers and constraints in relation to the structure of the
market model. As decisions about the model structure will have significant implications for
energy consumers for many years to come and energy consumers should understand those
implications now.
Public Service Obligation (PSO) Levy utilisation:
Consideration should be given to using a portion of the PSO to funding energy related
research & development both small scale and large scale; energy related information
campaigns designed to empower energy consumers and national campaigns to ensure
informed debate about the implications for all “energy citizens” of existing and future Energy
Policy ensuring greater public understanding of the long term nature of Energy Policy choices.
Grid 25 Project:
Consideration should be given to the potential benefits of Distributed Generation and CHP in
the context of supporting electrical transmission and distribution infrastructure and its
potential to integrate with the Grid 25 project using Smart Grid technologies.
Thank you for the opportunity to contribute to the consultation and Clarke Energy look forward to
further engagement on Energy Policy during the preparation of the White Paper. Please contact the
under signed for any clarification or further input on the topics raised herein.
Yours sincerely,
John Curley
General Manager
Clarke Energy Ireland Limited

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