The consultation for the forthcoming Renewable Electricity Support Scheme (RESS) ends today. Here is my submission :
A Floating Feed in Premium (FIP) which reduces over time to nil as the generators borrowings are paid down should be the primary financial support mechanism for the main RESS. This makes a lot of sense with regard to Irish wind energy which is now a mature technology, where there are no fuel costs and where Irish wind farms have access to the best wind resources in Europe.
I believe that LCOE is not a good measure for comparing different sources of generation. As is well known, the system effects of uncontrollable variable renewables are not adequately addressed by LCOE, since adding uncontrollable variable renewables to a system increases overall costs (new grid and operating procedures, suboptimal operation of the conventional fleet and new fast acting plant required as back up), all of which tends to reduce system productivity thus increasing costs. LCOE doesn’t capture this, so a Total System Cost analysis is required to discover what the probable effect would be on the consumer. This does not appear to have been carried out.
I therefore do not agree with the statement that “the least-cost RES-e mix would consist of mostly onshore wind”.
Indeed, the system costs will rise exponentially with the higher levels of wind proposed in RESS as conventional plant will be forced to run at far below their optimal efficiency*.
This means that the viability gaps of various renewable technologies are not comparable as stated in the RESS report. Some technologies incur less system costs (like biomass which can use the existing grid), some incur more.
In an analysis carried out by Irish Energy Blog, it was found that even without including the additional grid investment required for wind and other system costs, we have to spend € 1.00 on wind energy to replace 40 cents worth of fossil fuels. This does not represent value for money to the consumer nor is it a cost effective way of reducing fossil fuel imports. I would support instead investing in energy efficiency and in particular Passive Housing as a more cost effective way of reducing emissions.
Best wind location in Europe
“Ireland has one of the best onshore wind locations in Europe. Purely from a technical perspective, ignoring all other considerations, the unrestricted technical potential for onshore wind would be more than sufficient to meet Ireland’s energy needs”.
I fail to understand why, if the above statement is true, Irish onshore wind requires a high support scheme. Surely if Ireland has one of the best onshore wind locations in Europe, then a lower support scheme would be required than other European countries as the resource is greater.
In Germany, onshore wind receives € 4.66cent – 8.38cent per kWh (according to duration of payment) (§ 46 EEG 2017) minus €0.40 cent per kWh (§ 53 no. 2 EEG 2017) compared with € 6.72 cent per kWh (5.1 and 5.2 REFIT 2) in Ireland. The support scheme in Germany reduces over time which makes sense as the wind farms loans are paid down over the same period. A similar “reducing” scheme should now be adopted by Ireland given that Irish onshore wind is a mature technology and has access to the best wind resources in Europe. This would provide best value for money to the consumer. The support scheme should eventually reduce to nil after a fixed period of say 10 years.
This would ensure that our society is not locked into high energy costs for many years to come.
*Increased costs of combined cycle gas turbines (CCGT) running inefficiently to provide back up for when the wind does not blow were estimated to rise by €175 million per annum according to a 2014 Single Electricity Market report.