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