Southern Regional Assembly
Draft Regional Spatial and Economic Strategy
Gas Networks Ireland Response
8th March 2019
Introduction
Gas Networks Ireland (GNI) welcomes the opportunity to respond to the consultation on the Draft Regional Spatial and Economic Strategy issued by the Southern Regional Assembly.
GNI is a fully owned subsidiary of Ervia (formally known as Bord Gáis Éireann). It owns, operates, builds and maintains the gas network in Ireland and ensures the safe and reliable delivery of gas to its customers. The company transports natural gas through a 14,172km pipeline network. This supplies energy to over 688,000 customers, including businesses, domestic users and power stations. GNI believes that the gas network is integral to Ireland’s energy system and future.
GNI is driving environmental change for the benefit of all the citizens of Ireland through its development of CNG1 infrastructure for gas in transport, and renewable gas2 injection infrastructure.
GNI is supportive of the Draft Regional Spatial and Economic Strategy for the Southern Region, and would like to take this opportunity to highlight sections of the strategy where the gas network and the decarbonisation initiatives being carried out by GNI could be included and/or considered.
Draft Policy – Section GNI Comment Section 5: Environment; - Renewable gas, produced through anaerobic digestion (AD) can reduce carbon emissions, provide income and employment to rural communities and displace natural gas to reduce overall emissions. GNI suggests wording supporting AD is added to the strategy document. - Provide policy support to the Agricultural sector to develop AD, and to GNI as the provider of renewable gas injection infrastructure. - CNG for commercial vehicles can reduce carbon emissions from transport. - GNI believes renewable gas is the lowest cost option to decarbonising the domestic heat sector. - Renewable gas can contribute to the movement to decarbonisation, and support the circular economy. - Carbon capture and storage can contribute to the decarbonisation of the electricity sector through the use of abated natural gas power generation. - GNI is committed to preservation and biodiversity in all projects. - AD development can help the Southern Region become the “European Model Demonstrator Region of the Bio-Economy”. - GNI suggests the conversion of Moneypoint station to a gas powered generator as GNI believes this is the most cost effective and efficient solution for the site. - Consider how gas powered generation complements intermittent renewable electricity production in any new power generation developments. - GNI welcomes the provision of Energy Research funding. - GNI welcomes more data on local air quality, and believes CNG in transport can contribute positively to air quality. - GNI recommends Power to Gas (P2G) is included in the document. Section 8: Water and - GNI suggests that consideration be given to the role gas plays in Energy Utilities powering Data Centres and that wording is updated to reflect this.
1 Compressed Natural Gas (CNG) is a fuel used in the transport sector which reduces transport emissions. 2 Renewable Gas - GNI suggests that the GRAZE Gas3 project be included in the document as it is a large energy infrastructure project in the region. - GNI recommends that an additional point be added to RPO 217 to specifically support CNG infrastructure development. Section 9: - GNI is supportive of evaluation and evidence based policy making. Implementation
Section 5: Environment – Section 1 – Resource Efficiency & Transition to a Low Carbon Economy
With regard to the section on de-carbonising electricity, and in particular the need for low carbon technical solutions, GNI believes that carbon capture and storage (CCS4) can make a significant contribution. Due to the intermittent nature of renewables such as wind, complementary conventional generation such as gas powered generation is also required. When gas powered generation is combined with carbon capture and storage this results in significant decarbonisation of the electricity generated.
GNI’s parent company, Ervia, is currently working on a feasibility study to investigate using a depleted Kinsale Energy gas field to store carbon from two combined cycle gas turbine (CCGT) power plants in the surrounding area. Existing gas infrastructure which was previously used to bring gas from the field into the Irish gas network could be repurposed to transport carbon that has been captured into the gas field.
GNI supports de-carbonisation in the Transport Sector covered in RPO 87 and 89, and requests that RPO 87 be broadened in scope to refer to “moving to the use of clean generated electricity and renewable gas for private and public transportation by 2030”.
With respect to RPO 89, the rollout of a network of CNG refuelling facilities has commenced with 14 fast fill CNG stations being installed across the Core TEN-T road network via a project called the Causeway Study5 that is supported by the European Commission through the CEF Transport Fund6. In December 2018 a new public CNG station opened in Dublin Port. This project helps support the ‘National Policy Framework: Alternative Fuels Infrastructure for Transport in Ireland (2017 to 2030)’, which sets out a target network of 70 CNG refuelling stations by 20257. This document also forecasts Alternative Fuelled Vehicles for 2025 and 2030 i.e. 4,050 CNG commercial vehicles and 1,000 CNG buses in Ireland by 2025, growing to 6,050 CNG commercial vehicles and 1,500 CNG buses by 2030.
Under the Causeway Study, GNI offered a publicly available fund to support the purchase of CNG vehicles by commercial operators. This fund was fully subscribed and is helping fleet operators to transition some of their fleet to CNG which provides fuel savings of up to 35% compared to diesel. CNG is a mature and proven technology which delivers significant carbon savings compared to diesel, and also offers improved air quality with 99% less particulate matter, 70% less Nitrogen Oxide, and 80% less Sulphur Dioxide relative to diesel. When the production of renewable gas is increased on the gas network, and this gas is utilised by CNG vehicles as bio-CNG, carbon neutral transport can be
3 Green Renewable Agricultural Zero Emissions Gas 4 Carbon Capture and Storage 5 Causeway Study 6 CEF Transport Fund 7 National Policy Framework: Alternative Fuels Infrastructure for Transport in Ireland (2017-2030) achieved. CNG can contribute to decarbonisation of high energy usage vehicles, such as heavy goods vehicles (HGVs) and buses, where electricity is currently not a viable alternative to diesel.
De-carbonisation in the Agricultural Sector: GNI is supportive of RPO 90, and believes that the production of renewable gas through the anaerobic digestion of organic wastes and residues by the agri-sector will result in a reduction in greenhouse gas emissions within the sector. This reduction can be attributed to the following and more: - Avoided Methane Emissions from Slurry: Slurry naturally emits methane, a gas which is 28 times more potent than carbon dioxide when contributing to global warming. Sending these animal slurries to anaerobic digestion plants results in the capture of this methane, which can be used to replace natural gas in the gas grid. - Production of Digestate (High Potency Bio-fertiliser): There are carbon emissions associated with the production and transportation of chemical fertiliser products. Replacing this with digestate (a naturally occurring by-product of the anaerobic digestion process) will result in avoided emissions for the agri-sector. Additionally, as this digestate is of a high quality, its application to land can result in higher levels of carbon being sequestered into the soil, with the land becoming a carbon sink. - Utilisation of Agri Wastes and Catch/Rotation Cropping: The re-use of agricultural waste streams within the farm and catch cropping during periods of no rotation results in reduced emissions through better resource management and promoting the sequestration of carbon into the soil.
Anaerobic digestion plants provide additional revenue sources for rural communities, from the sale of feedstocks for the AD plants, bio-fertiliser and renewable gas. Additional employment is created as operators are needed to manage the anaerobic digestion plants. With ongoing uncertainty regarding agricultural exports to the UK, post Brexit supplementary income streams for farming are important. GNI suggests that another point be added to this section to highlight the benefits of anaerobic digestion for low carbon farming such as the following wording: “Anaerobic digestion utilises farm waste such as slurry to produce renewable gas and reduce agri emissions.”
GNI welcomes the inclusion of Green Infrastructure & Biodiversity in the document. GNI is committed to biodiversity & archaeology through the minimisation of the environmental impact of any construction and development activities8. This involves a partnership approach with environmental and heritage groups on all construction projects, as well as employing engineers and environmental specialists to carry out environmental assessments at the planning and construction phases of developments. GNI returns all land to its original state following construction. GNI is committed to archaeology preservation and has documented archaeological findings from completed projects.
GNI won the “Together for Biodiversity” award at the 2019 National Biodiversity Conference. At the conference GNI presented their “seeds for nature”9 – a suite of commitments for biodiversity from across Government, State Agencies and businesses. GNI has signed up to support the All-Ireland Pollinator Plan and has carried out specific internal biodiversity projects10.
GNI welcomes the opportunity to work closely with local authorities to preserve green infrastructure and biodiversity.
8 Gas Networks Biodiversity & Archaeology Commitment 9 'Seeds for Nature' at National Biodiversity Conference 10 Gas Networks Ireland Biodiversity Programme The section on Resource Efficiency talks about the Lisheen Bioeconomy Hub and how the Southern Region could become the “European Model Demonstrator Region of the Bio-Economy”. GNI is currently involved in a large project called the GRAZE Gas18 project, which aims to develop a renewable gas injection point in the Mitchelstown area and associated logistics. GNI believes that this project can contribute to the southern Demonstrator Region target. This project will support GNI’s goal of 20% renewable gas on the gas network by 2030. A reference to the Graze Gas project could be added to this section.
Renewable gas is a carbon neutral, sustainable fuel identical in performance to natural gas, therefore the existing gas network and customer equipment can be used without the need to upgrade. The MaREI Institute stated that “Green Gas is a commercially available indigenous solution to satisfy renewable heat and transport, and to avoid large incoming fines for neglecting EU targets in these sectors.”11
The section on Resource Efficiency also mentions Moneypoint power station. With regard to the issue of converting Moneypoint as called out in the NDP, GNI believes that conversion to a modern CCGT plant offers by far the most efficient and cost effective solution for the site in the long term. A CCGT plant offers the flexibility required for backing up intermittent renewable energy sources such as wind. The mix of non-renewables in power generation will move away from carbon intensive fuels, such as peat and coal, to lower-carbon fuels like natural gas.
In terms of “Integrating Renewable Energy Sources” (RPO 92), power to gas (P2G) represents a solution to energy storage in cases where renewable energy production (e.g. wind) exceeds customer demand on the electricity network and renewable energy is curtailed. This curtailed renewable energy could be used to produce hydrogen by electrolysis. The hydrogen could be added to anaerobic digestion plants to increase biomethane production. This biomethane can be injected directly into the gas network to increase the amount of renewable gas in the network. This technology should be considered now and potentially be a candidate for research funding under RPO 98. GNI suggests adding wording to acknowledge the potential of P2G in the Resource Efficiency section.
In relation to RPO 93 “Power Stations and Renewable Energy”, it should be noted that CCGT’s are ideal for backing up intermittent sources of renewable energy, and conventional generation will be needed to backup renewables and provide system stability.
“Indigenous Renewable Energy Production and Grid Injection” (RPO 96) is closely aligned with GNI’s own goal to have 20% renewable gas on the network by 2030. GNI is working towards this goal but requires the support of policy makers.
GNI believes that RPO 98 “Energy Research Funding” is a crucial objective to advance technologies and drive decarbonisation. GNI believes in the benefits of research and has a “Gas Innovation Fund12” to promote innovation in the gas industry, supported by the Commission for Regulation of Utilities (CRU).
“Energy Storage and Carbon Capture” is supported by GNI, and Ervia (GNI’s parent company) is working on a CCS feasibility study as previously mentioned.
11 MaREI Institute - Green Gas 12 Gas Innovation Fund Energy Efficiency In relation to RPO 101 GNI suggests that the objective is amended to include renewable gas as follows: “Clean Electric and Gas Heat Technologies; It is an objective to support initiatives to develop clean electric and Gas heat technologies in the region.”
GNI proposes this change because research by KPMG13 demonstrates that renewable gas is the lowest cost option for decarbonising the domestic heat sector. This is particularly true in the case of mature properties where expensive deep retrofits are required to bring building energy ratings (BER) to an A rating required for electric heating to work effectively. There are circa 300,000 homes currently located close by the gas network which use oil heating. These customers could be converted to gas to reduce carbon emissions.
GNI can assist in the delivery of RPO 103 by facilitating the injection of renewable gas to the gas network, which is a carbon neutral, sustainable fuel source. As previously stated, GNI is targeting 20% renewable gas on the gas network by 2030.
Circular Economy/Waste Anaerobic digestion plants use both animal and domestic wastes in the production of renewable gas, which is an efficient use of resources, thus supporting the circular economy.
Section 5: Environment – Section 3 – Creating a clean environment for a healthy society
Air Quality GNI is concerned about air quality, and welcomes the opening line of the Air Quality section which recognises the significant threat posed by particulate matter from the burning of solid fuels, and believes that caution should be exercised when considering solid biomass. GNI is supportive of RPO 126 on Air Quality and welcomes the collection of data on local air quality. Air quality benefits could be realised by converting coal/peat power generators to gas powered generation. In transport, the conversion of HGVs and buses from diesel to CNG would achieve an immediate improvement in air quality (99% less particulate matter, 70% less Nitrogen Oxide, and 80% less Sulphur Dioxide).
Section 6: Connectivity This section makes reference to EC Connecting Europe Facility (CEF) and the EU TEN-T Core Network. As previously mentioned GNI received funding from the CEF fund for the Causeway study, which encompasses works to develop 14 CNG fast fill stations across the TEN-T road network. CNG vehicles can contribute to an efficient road transport network while reducing the emissions from freight.
Section 8: Water and Energy Utilities
8.2 Strategic Energy Grid
Data Centres This section and associated RPOs appear to be focused on the electricity grid and don’t take into account the role that the gas network plays in powering Data Centres. Gas is favoured by large commercial customers with high energy consumption. GNI is connecting Data Centres to the gas network on an ongoing basis. This typically takes the form of a new natural gas connection to the data centre which utilises natural gas in CHP to generate electricity on site. Data Centres typically connect to the gas grid where the electricity infrastructure locally does not have capacity to meet their demand or it is economically favourable to use natural gas powered on site generation versus direct electrical grid connection.
13 Decarbonising Domestic Heating in Ireland Usually when connecting data centres, the existing gas infrastructure has sufficient capacity to accommodate them thus avoiding the need for network reinforcement. Connecting data centres to the gas network can also minimise the need for deep reinforcements on the electricity grid which supports the published June 2018 Government statement on the role of Data Centres in Irelands Enterprise Strategy referenced in this section.
GNI requests that RPO 211 be amended to include Gas Networks Ireland as set out below. “New Energy Infrastructure; It is an objective to support the sustainable reinforcement and provision of new energy infrastructure by EirGrid, ESB Networks, Gas Networks Ireland, and other key energy agencies (subject to appropriate environmental assessment and the planning process) to ensure the energy needs of future population and economic expansion within designated growth areas and across the Region can be delivered in a sustainable and timely manner and that capacity is available at local and regional scale to meet future needs.”
GNI makes this request because the Gas Network is a significant piece of energy infrastructure, with €2.5bn invested in the network to date. The network comprises both transmission and distribution pipelines, providing energy to power generation plants, industrial and commercial customers, and circa 700k domestic properties. In terms of electricity generation, approximately 51% of all electricity generated in Ireland comes from gas powered generation.
Section 8.3 Gas Networks GNI acknowledges the recognition that this section gives to renewable gas and its decarbonisation benefits. As previously mentioned, GNI has an objective to decarbonise the gas network and the first step is achieving a target of 20% renewable gas on the network by 2030. This objective can only be achieved with government and local policy support.
GNI strongly agrees that “natural gas and renewable gas are economically beneficial routes to a decarbonised heat sector”. Again re-iterating that renewable gas is the least cost option to decarbonisation in a large number of cases14, for both existing gas customers and the circa 300k oil heating users which are located in close proximity of the gas network. GNI is committed to injecting renewable gas into the gas network and suggests an update to the sentence below to include the GRAZE Gas project as follows:
“GNI is committed to integrating indigenous renewable gas production and grid injection, to facilitate and secure access to carbon neutral renewable gas for a large consumer base and is progressing renewable gas injection facility projects with Green Generation Ltd. and the larger GRAZE Gas project in Mitchelstown, to enable renewable gas to be injected into the network.”
For RPO 217, GNI recommends that the Assembly consider adding a fifth point to specifically support the roll out of CNG refuelling infrastructure in the Southern region for HGVs and buses. Suggested wording: “e. It is an objective to support the provision of CNG refuelling infrastructure which will help reduce carbon emissions, improve air quality and when coupled with renewable gas provide carbon neutral transport.”
Section 9. Implementation, Monitoring and Evaluation As a company which produces and utilises data in key decision making, GNI is supportive of evaluation and evidence based policy making.
14 Decarbonising Domestic Heating in Ireland Conclusion
GNI welcomes the Draft Southern Region’s Regional Spatial and Economic Policy and the inclusion of gas as a key energy source. GNI supports continued development of the gas network, so customers can enjoy the convenience, reliability and cost benefits of gas. GNI supports the expansion of the gas network to new areas or new towns in line with the CRU approved Connections Policy15 for gas which ensures that any further expansion of the network is completed in an economically viable manner. The summary table on the second page of this document provides a concise list of GNI’s main points which may assist in further developing the strategy document. GNI would welcome the opportunity to discuss this response in more detail and can provide further information on any of the topics discussed, if required.
15 Gas Networks Ireland Connections Policy Document