Submission to the DCCAE’s Consultation “Ireland’s Draft National Energy and Climate Plan (NECP) 2021-2030” Submission prepared by the Irish District Energy Association February 2019 www.districtenergy.ie [email protected] Submission to ‘Draft NECP’ Consultation from DCCAE: February 2019 Contents Contents ........................................................................................................................................................ 2 1 Introduction .......................................................................................................................................... 3 2 IrDEA welcomes the support for District Heating in the responses to the Initial NECP Consultation .. 3 3 The Potential for District Heating is much higher than proposed in the NECP .................................... 4 4 District Heating is a key enabler of Renewable Heat ............................................................................ 5 4.1 Excess Heat Should be Considered along with Renewable Heat as it also offsets carbon emitting fuels such as oil and gas ............................................................................................................................ 8 5 The Flexibility of District Heating Should be valued under Energy Security ......................................... 9 6 Increasing Renewable Heat will require stronger signals and/or support ......................................... 12 7 Bioenergy should be prioritised where it adds most value ................................................................ 12 8 District Heating can be a cost-effective form of Energy Efficiency ..................................................... 12 9 Policies and measures should include a mix of approaches ............................................................... 13 10 The impact assessment of planned policies and measures should use a holistic energy system approach ..................................................................................................................................................... 14 11 District heating could be a key research area in the NECP ............................................................. 14 2 Submission to ‘Draft NECP’ Consultation from DCCAE: February 2019 1 Introduction The Irish District Energy Association (IrDEA) promotes the development of District Heating & Cooling in Ireland. Countries with similar climates, populations, and energy systems to Ireland have proven that district energy can deliver sustainable and cost-effective heating to urban areas with millions of people. However, there is currently a major shortage of knowledge, capacity, standards, and regulations in Ireland to facilitate the implementation of large-scale district energy networks. IrDEA’s objective is to overcome these barriers, by informing key stakeholders in Ireland about all aspects of district energy. This document outlines the main observations and recommendations by IrDEA in the NECP which are: a) IrDEA welcomes the support for District Heating in the responses to the Initial NECP Consultation b) The Potential for District Heating is much higher than proposed in the NECP c) District Heating is a key enabler of Renewable Heat, although Excess Heat Should be Considered along with Renewable Heat as it also offsets carbon emitting fuels such as oil and gas d) The Flexibility of District Heating Should be valued under Energy Security e) Additional support will be require stronger signals for Renewable Heat f) Bioenergy should be prioritised where it adds most value g) District Heating can be a cost-effective form of Energy Efficiency h) The NECP should also set national targets and objectives for 2050 i) Policies and measures should include a mix of approaches j) The impact assessment of planned policies and measures should use a holistic energy system approach k) District heating could be a key research area in the NECP Each of these is elaborated upon in the remainder of this document. 2 IrDEA welcomes the support for District Heating in the responses to the Initial NECP Consultation IrDEA welcomes the fact that as part of the responses to the initial consultation on the NECP, “Issues consistently raised were the… development of district heating”. In the summary of these responses provided, IrDEA would like to highlight that district heating was recommended in relation to: • Energy efficiency: “District heating as part of a national heat plan is also proposed”; • Renewable Energy: “supports to all technology types including support for microgeneration and community owned projects, including district heating using waste heat” and “District heating and community participation should be encouraged along with the elimination of subsidies for peat burning”; • and Energy Poverty: “Any strategy should ensure fair access to all for new technologies, with policies to incorporate new energy production (including heat pumps/district heating”; 3 Submission to ‘Draft NECP’ Consultation from DCCAE: February 2019 Being mentioned across these variety of aspects demonstrates the multiple benefits that district heating has to offer, so IrDEA welcomes the strong support for district heating by respondents. 3 The Potential for District Heating is much higher than proposed in the NECP IrDEA believes that the ambition of 0.12 TWh should be substantially increased under the “National Targets in the NECP” and the potential should be updated in Section ii of “4.3 Dimension Energy efficiency” entitled “Current potential for the application of high-efficiency cogeneration and efficient district heating and cooling This section states that “In virtually all areas, alternative low carbon technology options at a building scale, such as heat pumps, can provide a more cost effective heat source than heat networks”. IrDEA is currently developing Ireland’s first All-Island heat atlas and the potential for district heating in Ireland is expected to show that ~30% of buildings in Ireland are located in areas suitable for district heating. This heat atlas is being developed by Europe’s leading researchers in the field of heat demand and heat source mapping, which uses peer-reviewed methodologies that have been developed and refined for over 5 years through the Heat Roadmap Europe project, and corroborated using actual measured heat demands in cities & towns across the EU. IrDEA requests that this statement is removed from the NECP until suitable evidence is provided to verify this claim. The results of the Irish Heat Atlas will be available before summer 2019. Heat mapping by Codema -Dublin’s Energy Agency, found that “Using the same thresholds for DH viability typically used by Danish energy planners in their own municipality areas, over 75% of the small areas in Dublin City would be classified as suitable for DH”1: this equates to approximately 4 TWh which shows there is scope to grow well beyond the 0.12 TWh target in the NECP. IrDEA recommends that a higher target is set for 2030 considering this potential. Also, to ensure district heating sector is stimulated, IrDEA recommends a policy is introduced in the NECP that requires local authorities in Ireland to map, identify and designate areas for district heating in the future. This type of planning policy is already outlined in the Eastern and Midland Regional Assembly’s Draft Regional Spatial & Economic Strategy; e.g. policy RPO 7.34 “EMRA shall, in conjunction with Local Authorities in the Region, identify Strategic Energy Zones as areas suitable for larger energy generating projects, the role of community and micro energy production in urban and rural settings and the potential for renewable energy within industrial areas” and RPO 7.37 “Local Authorities shall consider the use of heat mapping to support developments which deliver energy efficiency and the recovery of energy that 1 http://www.codema.ie/images/uploads/docs/Dublin_City_Spatial_Energy_Demand_Analysis_June_2015.pdf 4 Submission to ‘Draft NECP’ Consultation from DCCAE: February 2019 would otherwise be wasted. A feasibility assessment for district heating in Local Authority areas shall be carried out and statutory planning documents shall identify local waste heat sources.” Figure 1: Total Heat Demand Density of All Sectors in Dublin City (TJ/km2)2 When evaluating cost effectiveness of heat sources it is important to take account of all costs of delivery. Heat pumps for instance will electrify heat but moving the thermal demand to the electrical grid from gas or oil supply has a cost to the wider electrical network such as new substations, HV networks, generation capacity etc. The additional cost of these electrical grid upgrades is significant and should be included in any economic comparison of HPs implementation on a large scale compared to district heating. 4 District Heating is a key enabler of Renewable Heat Renewable heat will need to grow rapidly over the coming decade, due to a historically poor performance and also as it is part of the non-ETS sector, which has a binding CO2 reduction target of 30%. IrDEA welcomes the ambitious growth in renewable heat, but considering the scale of the this ambition, it is important that additional policies are put in place to support more renewable heat and IrDEA proposes that district heating is one option which can deliver more consider the potential outlined in section 3. The countries with the highest renewable heat targets in Europe have developed district heating so this is a proven way to provide renewable heat