Energy Saving Trust response to ‘Energy Strategy for Northern Ireland: Consultation on Policy Options’ Contents Context, strategic framework and scenarios to net zero ..................................................................... 1 Placing You at the Heart of our Energy Future .................................................................................................. 7 Grow a Green Economy ............................................................................................................................................................ 18 Develop a Low Carbon Skilled Workforce ........................................................................................................... 25 Do more with less ........................................................................................................................................................................... 28 Replace Fossil Fuels with Indigenous Renewables ................................................................................... 43 Transport .................................................................................................................................................................................................. 53 Create a Flexible and Integrated Energy System ...................................................................................... 59 Heat networks ...................................................................................................................................................................................... 61 Context, strategic framework and scenarios to net zero Q1. Do you agree with the overall goal of achieving net zero carbon energy no later than 2050? Yes. The climate emergency is urgent, and swift action is needed to progress towards a decarbonised future. We recognise the desire to set ambitious targets (such as net zero energy by or before 2050), and we support the delivery of decarbonisation at pace. It is our view that as far as possible climate targets and budgets should be evidence-based, this favours the approach proposed within this Policy Options consultation. We think it is essential that consumers are at the heart of the strategy. This consumer centric view is vital, as the strategy will only be successful if people are taken along with it. Northern Ireland has particular challenges, with 68% of homes heater by oil boilers, higher levels of fuel poverty than elsewhere in the UK, high reliance on personal vehicles and under-developed electric vehicle (EV) infrastructure. Achieving overall or energy sector decarbonisation earlier than the date proposed in this consultation would prove challenging given the nature of emissions in Northern Ireland as highlighted by the Climate Change Committee (CCC). The impressive progress made in rolling out renewables in Northern Ireland over the past decade is encouraging. If reducing emissions from the energy sector proves to be easier than previously predicted (e.g. further dramatic reductions in the price of renewables or home retrofitting) timelines should be adjusted. It is good to see a willingness to adjust target dates to reflect changes in circumstance in the consultation document but we believe that there should be periodic reviews of progress towards this target, with the potential to strengthen targets if possible. It is important that flexibility be built into the Strategy to account for any emerging evidence or change in circumstance. Q2. Do you agree with the proposed vision of “net zero carbon and affordable energy” for the Energy Strategy? Yes. This aligns strongly with our own organisational vision and approach. Achieving net zero carbon energy in Northern Ireland as part of the wider UK net zero emissions target as soon as possible is critical. Our view is that adopting a ‘fabric first’ approach and focussing on energy efficiency will reduce the amount of energy required in homes, making the net zero carbon energy target easier to achieve while helping to address affordability by reducing energy bills. It is our view that the transition must be just and that the significant economic (as well as social, wellbeing etc) benefits of this change should be equitably distributed. Northern Ireland is well-placed to capitalise on the economic opportunities that will result from action to combat climate change including investments in renewables, improving the thermal efficiency of homes and transitioning to a decarbonised transport system. Q3: Do the five principles identified provide clear direction around the approach that we want to take with the Energy Strategy? Placing you at the heart of our energy future; Grow a green economy; Do more with less [energy efficiency]; Replace fossil fuels with indigenous renewables; Create a flexible and integrated energy system Yes. Overall, we welcome the five guiding principles. They look to offer a balance between rapid decarbonisation, fairness for consumers, and economic sustainability while looking forward to the role of flexibility and integration to deliver a net zero Northern Ireland. In particular we welcome the focus on energy efficiency. Energy efficiency reduces the costs of energy for consumers by reducing their bills. The Northern Ireland Sustainable Energy Programme (NISEP), which is delivered by Energy Saving Trust and targets vulnerable customers, has been successful in delivering energy efficiency upgrades across both the domestic and commercial sectors. While we support the desire to grow the renewable energy sector in Northern Ireland and source renewable energy from indigenous sources as much as possible, greater interconnection between NI and the Republic of Ireland (particularly the proposed North-South interconnector) and between NI and Great Britain offer significant opportunities alongside indigenous renewables to decarbonise the power sector at lower cost and maximise the use of renewable energy overall. It is our view that this approach should not be ruled out if it means decarbonising more rapidly at lower cost. We would also suggest that DfE considers including a sixth principle to support innovative local energy systems and community action along similar lines the to the fourth priority in the Scottish Government’s Energy Strategy (see page 10 of: https://www.gov.scot/publications/scottish-energy-strategy-future-energy- scotland-9781788515276/). While local energy has not been as prevalent in Northern Ireland as in other parts of the UK, a more decentralised, flexible, digital and renewable future energy system offers opportunities for communities to engage more directly with the transition. Communities who wish to do this should be supported in doing so as a key principle. The co-benefits of local and community energy projects have been well- documented in several regions and contexts (see: https://www.sciencedirect.com/science/article/abs/pii/S1364032118304507). These include: • emission reductions • improved energy efficiency • the stimulation of local economies and job creation • increased local awareness of climate and environmental issues • increased acceptance of renewables and the transition more generally (see: bit.ly/CEEbriefing). Through community benefit funds these projects also invest in services and support for local people (see: https://www.localenergy.scot/what-is-local- energy/community-benefits/). The transition to net zero will require significant changes to the way we live our lives. If communities feel invested in the transition it is more likely to be a success but this will not be achieved without their consent and involvement. By considering and adopting measures that involve communities to a greater degree, the process of transition can be made easier. Through our work delivering local energy-focused programmes for the Welsh and Scottish Governments (the Scottish Community and Renewables Energy Scheme (https://www.localenergy.scot/) and the Welsh Government Energy Service (https://energysavingtrust.org.uk/programme/welsh-government-energy- service/)) we have seen how community energy projects help with engagement and drive support for net zero.. More detail regarding our views on energy communities, the role they could play in the transition and how they can be supported can be found in our response to Question 77. Q4: Are there any key delivery priorities for the Energy Strategy not captured? If so, please outline what you believe should be included. – six priorities: Security of supply; Costs; Intelligence [R&D, data, pilots etc]; Legislation; Regulation [reviewing energy regulation to promote consumer interests]; Governance [delivering a coordinated and joined-up approach to energy decarbonisation across all levels of government]. See pg 25. The six priorities are welcome, particularly the focus on costs and consumer protection. There is a need for cross-departmental working and strengthened governance in order to ensure that efforts are not duplicated, action can be taken efficiently and it is clear who leads on given policy areas. This was recently highlighted in a Northern Ireland-focused report into the governance of the energy transition produced by University of Exeter academics and so it is good to see this as a key part of the Strategy. The report suggests the possibility of creating a dedicated ‘Department for Climate and Energy Transition’ where all decisions related to addressing climate change and the energy transition could be situated. An approach similar to this has recently been taken by the