Threat to the Environment is from Government Policy not Climate Change

There was some very positive news recently, as environmental campaigner Peter Sweetman, managed to quash an attempt by the Irish Government, specifically the Minister for Culture and Heritage, to remove protections for the rare Pearl Mussel in the river Blackwater. The Minister eventually admitted that they had breached the Strategic Environmental Directive (SEA) before the High Court Judge could rule. So on the one hand, the Government pays plenty of lip service to Climate Change and reducing emissions, but then sinisterly sets about destroying what's left of our environment. By so doing, it is able to lay the blame at "climate change" and divert blame away from itself.

The Department claimed that the protections for the pearl mussel would negatively affect their plans to urbanize more of Ireland's environment:

The Department meantime was made aware by Cork County Council and Irish Water that the inclusion of the 

pearl mussel in the qualifying interests for the Blackwater Main Channel was making it extremely difficult to allow 

developments to occur in the towns and villages along the river. Partly in that context, but mainly given the 

approach  recommended by the national expert, the Department decided that the Blackwater Main Channel 

should be removed  from the First Schedule to the 2009 Regulations, while retaining two tributaries, the Allow 

and Lickey.

And of course, the national experts, the ones who's job it is to restrain stupidity, are the very 

ones giving credence to it. 

Well done to Peter Sweetman for doing the job that our well funded NGOs are supposed to be 

doing. 

New Energy Minister Scare-Mongers About Fines

by Pat Swords

Scare mongering about fines seems to be all the fashion these days. However, let's face it, the fact that the renewable programme was so dysfunctional that they couldn't get it to work was really their fault, if they had done an SEA and Regulatory Impact Analysis, as they were legally required, they would have found out before they started that it wasn't going to work. 

However, there is another angle to that, namely Article 4(4) of the Directive:

• 4.   A Member State whose share of energy from renewable sources fell below the indicative trajectory in the immediately preceding two-year period set out in part B of Annex I, shall submit an amended national renewable energy action plan to the Commission by 30 June of the following year, setting out adequate and proportionate measures to rejoin, within a reasonable timetable, the indicative trajectory in part B of Annex I.

• The Commission may, if the Member State has not met the indicative trajectory by a limited margin, and taking due account of the current and future measures taken by the Member State, adopt a decision to release the Member State from the obligation to submit an amended national renewable energy action plan.

I was pointing this out in my recent correspondence to UNECE, Ireland has fallen way behind its NREAP trajectory, so has the Netherlands.

The European Environment Agency has just recently updated its webpage with an analysis for each Member State based on 2017 data - click on a country and then scroll the tab until you get to Progress on Renewable Energy:

https://www.eea.europa.eu/themes/climate/trends-and-projections-in-europe/climate-and-energy-country-profiles 

So Ireland in 2017 was 10.8% (they squeezed a bit more!) but versus 11.9% in NREAP Trajectory. In 2016 it was 9.5% versus 10.7%. Bottom line, they should be doing a new NREAP with proper SEA, etc., as the graph below shows they have been below the target now for several years and not getting any nearer to catching up with it. So where is that legally required new NREAP? There is no point in threatening us the public with fines, when the reason they are in a mess is a failure to properly comply with the law and come up with something, which wasn't so dysfunctional.

The Netherlands are doing even worse than Ireland :

France's situation is deteriorating also :  

Luxembourg hasn't a hope of catching up :

Malta's gap just got huge :

Cyprus is actually going downhill, must have been some dodgy previous reporting there : 

Slovenia is also going downhill :

The sensible Poles just don't seemed to be bothered about this silly renewable programme anymore :

National Development Plan Short on Sums

Last week, the Government announced their plans for long term infrastructure spending that we, the already overtaxed taxpayer, will have to pay for. As is usual with these big PR events, they are big on glossy brochures but short on facts and critical analysis. Somehow the cognitive dissonance of Ministers announcing investments in airports while at the same time allocating €22bn to help fight "climate change" was lost on most of our media.

In this article, Pat Swords explores one part of the plan - electric cars.

This week our 'rulers' announced their plan for 2040. Let's just focus on one 'trendy' aspect:

• At least 500,000 electric vehicles on the road by 2030 with additional charging infrastructure to cater for planned growth
• No new non-zero emission vehicles to be sold in Ireland post 2030
• No NCT Cert will be issued for non-zero emission cars post 2045
• http://www.gov.ie/en/pdf-viewer/?file=https://s3-eu-west-1.amazonaws.com/govieassets/18/5569359-NDP%20strategy%202018-2027_WEB.pdf#page=76  

So lets look at some simple sums, not a strong point of our glorious rulers, but relevant for plans which are meaningful and don't end up as an awful mess. To put the above into perspective, the CSO figures tell us that we have some 2 million cars in this so called 'Republic'. I accept that if one has enough money to buy a top range Tesla, one gets a 100 kWh battery pack, which on a good day can do something close to 400 km. This is what one is entitled to expect from what is a 'car' after all. However, the problem is when one needs to recharge it, as a domestic house is typically only set up for 7 kWh. So if you turn off all your other electrical appliances and wait 14 hours, you'll be ready to go again. Not very practical is it?

However, not to despair as they are going to build out new charging infrastructure for us instead. Well that 100 kWh battery may theoretically be 'supercharged' in something like 30 minutes, but let's assume that such a charging point can charge three such Teslas in an hour. This means that it has to deliver 300 kWh in an hour equivalent to 0.3 MW. So if we build a thousand of these, we then need a 300 MW power station to supply them. By international standards, this is a medium sized power station, which would be comfortably able to cover 10% of the average demand currently on the Irish grid. 

So in simple terms if you want to be able to charge 3,000 electric cars in an hour, which is only 0.15% of the number of cars out there, you need a new 300 MW power plant, which is a large enough to cover 10% of the current country's demand. It's pretty obvious that unless you string up the country with new power stations and pylons, none of this is going to work, unless the public is prepared to spend a lot of their hard earned cash on electrical vehicles, which they will just have to park most of the time, as they don't have the hours to stand in line, awaiting an opportunity to get a charge in at one of these new 'charging infrastructures'. 

This is actually some pretty basis stuff and you would think that before they go off announcing their grandiose plans, they would have thought about it first. After all the data is published and readily available, such as from the SEAI's annual publications:

http://www.seai.ie/resources/publications/Energy-in-Ireland-1990-2015.pdf 

Transport uses some 42% of energy consumed in Ireland, more than double that which goes into electricity generation. If that energy demand is to be switched from fossil fueled vehicles to electric vehicles, then the electricity infrastructure we have would need to be more than doubled, even allowing for the fact, that the current grid is somewhat lightly loaded at night. Think about this one, you get an allocated slot to drive your Tesla to the new charging infrastructure to hook it up between 2.30 and 3.00 am - is this progress?.

And what of the alleged CO2 savings ? 

• An electric car with a 100kWh battery has thus emitted 15-20 tons of carbon dioxide even before the vehicle ignition is turned on. This calculation assumes a 50-70 per cent fossil share in the electricity mix. 
• https://www.ivl.se/english/startpage/top-menu/pressroom/press-releases/press-releases---arkiv/2017-06-21-new-report-highlights-climate-footprint-of-electric-car-battery-production.html 

If you were to buy a Fiat Punto, which does 120 g of CO2 per km, you could drive it for nearly 170,000 km before you would have emitted the same 20 tonnes of carbon dioxide. 

When one does simple sums, none of this makes the slightest sense, not least as to the why? We don't have an urban air pollution problem in our cities and the weather is just doing its own thing, claims of weather doomsdays are just wild speculation and with each increasing year it is clearly obvious how wildly speculative those claims are. So in essence electric vehicles are a trendy solution to a problem, which has never been assessed and quantified and actually doesn't currently exist. So why do we end up with this dysfunctionality? After all the Government's own procedures highlight:

• Regulations and their implementation often result in considerable costs to the public service, to citizens and to businesses. It is important that these costs are taken into account.  Regulatory Impact Assessment (RIA) is a tool to assess the likely effects of a proposed new regulation and involves a detailed analysis to:
• (i) ascertain whether or not the new regulation would have the desired impact and
• (ii) to identify the costs and benefits associated with the regulation.

Can't find a Regulatory Impact Analysis for this Project Ireland 2040 and above announced regulatory changes with respect to vehicles in Ireland. However, there was a Strategic Environmental Assessment completed for this Project Ireland 2040, but there is no assessment in it at all with respect to what has now been adopted above with regard to electric vehicles:

• http://npf.ie/wp-content/uploads/2017/09/Environmental-Report-%E2%80%93-Ireland-2040.pdf 

Theoretically the Lisbon Treaty, which we voted for, states in its Article 3 that we have a  right to a "highly competitive social market economy". As far as I'm concerned, what car I choose to buy is my business and why should I be dictated to by some barmy ideological politician? I would also recommend that one spend some time talking to older Eastern Europeans about the 45 years they spent behind the Iron Curtain and subject to the rigours of a planned economy there. This whole proposal is an outrageous abuse. It is not the State's entitlement or function to intervene in the free market in this manner, not least as it doesn't have a single scrap of analysis to justify the position it has now adopted. 

After all oil in 2014 was $110 a barrel and due to the technology advances brought on by fracking, has reduced to a value consistently around $55. While we have not seen all of that benefit, due to the degree of tax on these fuels, we have seen quite a benefit due to the market forces, which control supply and demand of this energy source. On the other hand, the electricity market in Europe is totally distorted by political intervention, costs have soared out of control and we saw how recently Viridian with two perfectly good power stations in Dublin simply decided to walk away from them, as the electricity market place is such a distorted mess here. So why on earth would anybody in their right mind want to be forced by the State to buy a vehicle, for which the facilities to refuel it are completely inadequate and the fuel supply is from a completely distorted market place lacking in transparency and demonstrating no shortage of political interference? In other words cronyism and a lack of accountability, which is breeding corruption.  

Factcheck Energy Minister

Richard Boyd Barrett, one of the most capable politicians in the country, gave Energy Minister Denis Naughten a grilling in the Dail on Tuesday over his energy plans.  Barrett claimed that wind energy gets 80% of the PSO. The Minister disagreed but didnt have the figures to hand.

FACTCHECK : Wind gets about 67% of the PSO, peat gets 29% with the remaining 4% going to other renewables*.  

FACTCHECK : There is a legal process for assessing plans and programmes. It is not up to Deputy Dooley or Naughten to decide what route we should go down. A Cost Benefit Analysis needs to underpin this type of decision making where billions are at stake, not what Deputy Dooley happens to think is a good idea.

FACTCHECK : It is true that the wind energy guidelines are subject to strategic environmental assessment (SEA). However, an SEA is required for all public plans and programmes. The Government's Renewable Energy Plan (NREAP) has never been subject to an SEA. 

FACTCHECK : The 3-4% savings figure from wind is an overall emissions figure that includes other sectors like transport, heating and agriculture. Last year, there was a 4.9% increase in energy use. Transport's share of overall energy use rose from 33% to 42% in 2015.  So the savings made from installing wind farms are being more than wiped out by rises in other sectors. Yet the political and (Fake) News narrative is still all about electricity generation. 

*I have taken out the clawbacks from security of supply (gas) as they distort the PSO figure. Biomas, biogas and hydro made up about 5% of electricity generation in 2015 according to SEAI.   This means that wind received € 286 million from PSO.  

Offshore Renewable Energy Strategic Environmental Assessment

In 2010, the Department of Energy and SEAI prepared a Strategic Environmental Assessment (SEA) for their Offshore Renewable Energy Development Plan (OREDP). To comply with the SEA Directive, alternatives to the Plan were considered, including the option not to implement the plan. So were these alternatives assessed correctly ?

It is accepted that there will be environmental impacts :

The SEA has identified that, in some locations, there is potential for the development of offshore wind, wave and tidal energy to have likely significant adverse effects on the environment. This is mainly off the west coast of Ireland which is recognised as being of significant environment and seascape/landscape importance/value. 

So considering that we are looking at significant and irreversible impacts on our coastal and ocean environment (and species), what are the impacts of not implementing the plan ?

Potential effects relating to not combating climate change such of continued effects on temperature, sea levels, precipitation, storminess, sea temperatures and these effects of these on species and habitat distribution and abundance, food chains etc. 

 This is misleading for two reasons. Firstly, whatever Ireland does to combat climate change will be reversed by many multiples by China and India who are building coal plants to meet their world record energy demands. If we even look closer to home, the Netherlands are building three new coal plants with total capacity equal to four Moneypoint coal power stations. Germany are also reliant on new coal power stations :

Water vapour rises from the cooling towers of a brown coal power station in Germany

Ireland does not have a separate climate to Netherlands, Germany or China so if man made climate change will result in an environmental catastrophe here in Ireland, the decisions which can prevent it will need to be taken outside Ireland.

Secondly, the effect of climate change on temperature is still uncertain. The raw records (as opposed to the modified ones) from Valentia Observatory show no remarkable increase in temperature :

http://irishenergyblog.blogspot.ie/2015/03/facts-or-fiction-is-green-movement.html

Indeed, understanding of the climate and the mechanisms that control it is still not properly understood by scientists. It was alleged by James Delingpole that the following extract from the draft IPCC report was altered for the Summary for Policy Makers :

None of the studies cited above has shown clear evidence that we can attribute the observed changes to the specific case of increases in greenhouse gases [sic]. No study to date has positively attributed all or part of the climate change  observed to man made causes. Any claims of positive detection and attribution of significant climate change are likely to remain controversial until uncertainties in the total natural variability of the climate system are reduced. Will an anthropogenic climate [signal] be identified. It is not surprising that the best answer to the question is  “ We don’t know”.

This extract now seems to be deleted from the IPCC website since 2011 :

http://www.ipcc.ch/climate-changes-1995/ipcc-2nd-assessment/2nd-assessment-en.pdf.


So there is absolutely no certainty that the negative impacts on the environment in the "Not Implementing the Offshore Renewable Plan" will actually occur or indeed that Ireland can do anything to prevent it anyhow.

But it is a certain certainty that there will be significant impacts on the ocean and its habitats by installing renewable energy and offshore grid infrastructure in implementing this plan.

So the impact on the Irish environment from climate change is both uncertain and out of our hands in any case and should not be included in this assessment. But the environmental impact of going ahead with this plan is both certain and as a direct result of actions the Irish government take. Therefore, the latter needs to be given full consideration in the assessment.

Other impacts include volatility of prices of electricity from fossil fuels and the implications of these on business/enterprise in Ireland as well as the effects on domestic customers in terms of fuel poverty etc. 

This should not be an issue as the reverse is actually true. Offshore energy will require a higher subsidy than onshore energy due to its higher capital costs. As onshore renewable energy is already higher than fossil fuel generated energy, offshore will then be even higher. There are also extra costs from further increasing the surplus of generation capacity and installing a new grid. So electricity bills will increase from implementing the plan, not from not implementing it.

Limitations relating to intermittency of supply from onshore wind. In comparison tidal energy is much more predictable and constant and offshore wind is generally less intermittent. 

Once again, there is no actual evidence to back this up.  The following graph comes from a presentation by Mark O'Malley of UCD Engineering Department :

 We can see that there is a high correlation of wind and wave energy. In otherwords, when the wind is blowing, so too are the waves rolling. And vice versa.  Offshore wind does tend to have higher capacity factors (i.e. output) but would still be classified as non dispatchable i.e. it can't be switched on at will unlike a conventional plant.

So the benefits of this enormous plan are still not clear to the ordinary citizen. The benefits to the country from not implementing it are also not made clear - maintenance of our pristine ocean environment and habitat, lower energy costs and therefore more jobs, less surplus capacity, more reliable electricity and improved tourism image (which also results in more jobs).

The SEA Directive states :

Member States shall ensure that environmental reports are of a sufficient quality to meet the requirements of this Directive

What do you think - is this assessment of "sufficient quality"  and an examination of all alternatives when all options are open or is it just rubber-stamping of a decision already made ?