isi-012 complete submission to dcenr on solar renewable energy, final, 18-sep-15

Irish Solar Innovations

Submission)to)the)Department)of)Communications,)Energy)and)Natural)Resources)

))

PHOTOVOLTAIC)SOLAR)ENERGY)AS)AN)APPROPRIATE)TECHNOLOGY)FOR)THE)SUPPLY)OF)ELECTRICITY)FROM)

A)CONTINUOUSLY)RENEWABLE)RESOURCE)

Prepared on behalf of

Irish Solar Innovations Limited

Environmental Management Services Outer Courtyard,

Tullynally, Castlepollard,

County Westmeath !!

18)September)2015)

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Irish&Solar&Innovations&Ltd!

c/o!Environmental&Management&Services&Outer!Courtyard!

Tullynally!

Castlepollard!

County!Westmeath!

!

18!September!2015!

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!

Decarbonisation!Division,!!

Department!of!Communications,!Energy!and!Natural!Resources,!!

29G31!Adelaide!Road,!!

Dublin!2.!

By!email!to:[email protected]!

!

!

Dear!Sir,!

!

Submission&to&the&Department&of&Communications,&Energy&and&Natural&Resources&on&Solar&Energy&as&an&Appropriate&Technology&for&the&Supply&of&Electricity&from&a&

Continuously&Renewable&Resource&!

In! response! to! the! Department’s! Renewable! Electricity! Support! Scheme! Technology!

Review!Consultation,!2015,!Irish&Solar&Innovations&welcomes!this!public!consultation,!

and!we!are!pleased!to!have!the!opportunity!of!making!a!submission.!

!

The!primary!purpose!of!our!submission! is!to!demonstrate!that!renewable!generation!

of! electricity! by! solar! PV! has! the! appropriate! characteristics! to! make! a! major!

contribution! to! Ireland’s! transition! from! a! largely! fossil! fuel! based! economy! to! one!

based!on!renewable!energy,!to! improve!energy!security,!and!to!assist! in!meeting!the!

targets!and!challenges!identified!in!the!Department’s!consultation!document.!!!

!

We! also! hope! that! the! Department! will! take! appropriate! steps! to! ensure! that! the!

advantages! of! solar! photovoltaic! electricity! are! widely! and! fully! understood! and!

appreciated,! and! that! this! technology! will! take! its! place! among! other! sources! of!

renewable! energy! in! Ireland.! ! In! order! to! achieve! this! aim,! we! believe! that! DCENR!

should!embark!on!a!proactive!public!awareness!campaign!to!clearly!demonstrate!the!

benefits!of!solar!PV!energy.!

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Lastly,!and!of!the!greatest! importance,! Irish&Solar& Innovations&urges!the!Department!

of! Communications,! Energy! and!Natural! Resources! to! expedite! the! introduction! and!


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implementation!of!a!competitive!solar!PV!Renewable!Energy!FeedGin!Tariff!(REFIT),!so!

as! to! benefit! smallGscale,!mediumGscale! and! largeGscale! producers.! !We! believe! that!

this!is!essential!to!make!solar!PV!electricity!more!competitive,!would!help!to!increase!

the! amount! of! solar! PV! installed,! and! would! generate! more! examples! to! further!

demonstrate!the!technology’s!financial,!social!and!environmental!advantages.!!

!

We!consider!that!the!difference!in!policy!and!practice!between!the!Republic!of!Ireland!

and! Northern! Ireland! in! relation! to! the! availability! of! a! feedGin! tariff! constitutes! a!

distortion!of!the!market!for!solar!PV,!and!it!is!hard!to!understand!the!reason!for!this,!

given! that! a! single! electricity! market! has! operated! since! 2007,! with! wholesale!

electricity! prices! being! determined! on! an! AllGIreland! basis.! ! Irish& Solar& Innovations&would!therefore!urge!DCENR!to!level!this!“playing!field”,!so!that!a!similar!business!case!

could!be!made!for!investment!in!solar!PV!on!either!side!of!the!border.!

!

An! electronic! copy! of! our! submission! is! attached,! and! we! trust! that! DCENR! will!

consider!the!above!brief!points!in!this!covering!letter!as!part!of!our!overall!submission;!

and!we!look!forward!to!the!Energy!Policy!White!Paper!in!due!course.!

!

Yours!sincerely,!

!

Jack!O’Sullivan!

On&behalf&of&Irish&Solar&Innovations&Limited&!

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!ISIG010!Letter!to!DCENR!with!submission!on!solar!renewable!energy,!18GSeptG15.doc!


Submission to the Department of Communications,

Energy and Natural Resources on Photovoltaic Solar Energy as an Appropriate Technology for the

Supply of Electricity from a Continuously Renewable Resource

Submitted in response to the Department’s Renewable Electricity

Support Scheme Technology Review Consultation, 2015

18 September 2015 1. INTRODUCTION In July 2015, the Department of Communications, Energy and Natural Resources issued a consultation document1 for the purpose of seeking views on the available technologies for the generation of electricity from renewable resources, the cost-effectiveness of these technologies, and the level of Government financial and other support required to ensure an adequate and appropriate level of uptake. The consultation is part of a wider process aimed at the development of a new support scheme from 2016 onwards, for electricity generated from renewable resources, and to contribute to the forthcoming Energy Policy White Paper, to be published in October 2015. The new support scheme will also take into account the results of the public consultation on the Green Paper on Energy Policy which was published in May 2014. The importance of renewable sources of energy has previously been emphasised in the Strategy for Renewable Energy 2012 – 20202 , which stated that the development of renewable energy is central to overall energy policy in Ireland: “renewable energy reduces dependence on fossil fuels, improves security of supply, and reduces greenhouse gas emissions creating environmental benefits 1 Renewable Electricity Support Scheme -- Technology Review Consultation. Department of

Communications, Energy and Natural Resources, July 2015. 2 Strategy for Renewable Energy: 2012 – 2020. Department of Communications, Energy and

Natural Resources.

Submission by Irish Solar Innovations to the Department of

Communications, Energy and Natural Resources

18 September 2015 Page 2 of 26

while delivering green jobs to the economy, thus contributing to national competitiveness and the jobs and growth agenda”. The Strategy for Renewable Energy identified five strategic goals:

• Generating more renewable electricity from onshore and offshore wind power for the domestic and export markets;

• Building a sustainable bioenergy sector supporting renewable heat, transport and power generation;

• Fostering research and development of renewable technologies including wave and tidal;

• Increasing sustainable energy use in transport through the use of biofuels and electrification; and,

• Building an intelligent, robust and efficient electricity network system. The Strategy failed to mention solar photovoltaic, and placed great emphasis on the utilisation of wind power. Other over-arching determinants of Ireland’s renewable energy policy include the 2009 EU Renewable Energy Directive, under which Ireland has been given a legally binding target of meeting 16% of the country’s energy requirements from renewable sources by 2020. Ireland is committed to meeting 40% of electricity demand from renewable sources, as well as 12% in heat and 10% in transport. More recently, at the European Council meeting on 23 and 24 October 2014, agreement was reached on Europe Union targets for the Climate and Energy Policy Framework3, including:4 i) a binding EU target of at least 40% reduction in greenhouse gas emissions

by 2030, compared to 1990; ii) an EU target of at least 27% for the share of renewable energy consumed in

the EU in 2030; this target will be binding at EU level, and must be fulfilled through Member States contributions guided by the need to deliver collectively the EU target without preventing Member States from setting their own more ambitious national targets; and,

iii) an indicative target of at least 27% increase in energy efficiency by 2030. 3 European Commission, 2014. Communication from the Commission to the European

Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: A Policy Framework for Climate and Energy in the Period from 2020 to 2030. COM(2014) 15 final; Brussels, 22.1.2014.

4 European Council Conclusions, Brussels, 24 October 2014; EUCO 169/14 (Note from the General Secretariat of the Council, to Delegations).




In Ireland, the Department’s Technology Review Consultation document notes that these targets will require emissions reductions of 43% and 30% respectively over the 2005 levels for participants in the Emissions Trading Scheme (ETS) and for the non-ETS sectors. The document observes that “while good progress has been made to date, our 2020 targets continue to be challenging”, and “regulatory certainty is needed to provide the platform for promoters to continue to access funding and progress their projects”.5 Looking to the very near future, EU environment ministers will meet in Brussels on Friday 18 September, after which they are expected to announce that the EU will press for targets of a global 60% emissions cut by 2050, and 100% emissions reduction by 2100, despite the initial objections of Poland, Hungary, and the Czech Republic. Agreement among Member States is needed to ensure that EU negotiators can push for a strong international framework to limit global warming to no more than two degrees higher than pre-industrial levels. The proposed emission cuts will have to be soundly based and defended, in order to increase the probability of securing a legally binding cap on global warming at the United Nations Climate Change Conference (COP21) in Paris in November. It is therefore clear that not only are the agreed emission reduction targets quite challenging, but that more serious challenges lie ahead in order to reduce and eventually eliminate dependency on fossil fuels as our principal source of energy. These critical issues are clearly recognised by the Minister for Communications, Energy and Natural Resources, Mr Alex White, T.D., in his address to the conference on Ireland’s Energy Transition, at Dublin Castle,6 on 03 June 2015, when he stated that:

“The impact of global warming demands that we put sustainability at the very centre of our energy policy. The scale of the challenge was starkly outlined in the report of the Intergovernmental Panel on Climate Change, which informed the Lima conference. It is now absolutely clear that the world must replace gas and coal with renewable energy sources within 35 years.

Our vision here must be equally clear and equally ambitious. We must and we will transform Ireland’s energy production and consumption patterns so that, by 2050, our system will be largely decarbonised.

This vision comes with a pledge to all our citizens, our communities, industry, and those who work to provide energy to our homes and

5 Renewable Electricity Support Scheme -- Technology Review Consultation; Introduction,

paragraphs 1.2 and 1.3. Department of Communications, Energy and Natural Resources, July 2015.

6 http://www.dcenr.gov.ie/news-and-media/en-ie/Pages/Speech/Alex-White-Minister-for-Communications-Energy-and-Natural-Resources-Irelands-Energy-Transition.aspx




workplaces that policy will ensure certainty, stability and affordability, as we make the transition to a low carbon future”.

When referring to renewable sources of electricity, the Minister stated that:

“Onshore wind has so far been at the centre of Ireland’s renewable energy generation. It has served us well, and it will continue to do so. But the next period of energy transition will also see the development of new commercial and late-stage solutions, which are likely to change the mix of renewables as technologies like solar PV [our emphasis], off-shore wind, and carbon capture and storage mature, and become more cost-effective”.

The Minister’s reference to solar PV is most welcome, and provides an additional basis for our submission that solar photovoltaic can be a very significant source of electricity for Ireland’s future needs. In this submission, Irish Solar Innovations hopes to demonstrate that solar PV possesses appropriate characteristics to make a major contribution to Ireland’s transition from a largely fossil fuel based economy to one based on renewable energy, and to assist in meeting the targets and challenges mentioned above. We are pleased to have the opportunity of making a submission, and look forward to the Energy Policy White Paper in due course.




2. IRISH SOLAR INNOVATIONS 2.1 Who We Are Irish Solar Innovations Limited is a relative newcomer to the solar energy market in Ireland, having been established on 29 July 2015 (Registration number 565738). However, the company brings with it a wealth of experience, as its current directors and personnel have previously been involved in solar and other renewable energy systems. Irish Solar Innovations Ltd (ISI Ltd) offers a full range of services from initial feasibility studies to turnkey installations, specialising in the design and installation of solar photovoltaic systems from 4KW to 50Megawatt, especially medium-scale solar energy arrays to provide electricity to farms, manufacturing plants and other commercial, local authority and community developments, with the option to export excess electricity to the grid. The company includes in its team a number of the most experienced electrical engineers, and the directors and principal consultants have been involved in energy conservation and solar energy for many years. ISI Ltd understands the solar energy market; but, more importantly, the company also has as one of its primary aims the delivery of turnkey solution to meet the needs of clients. The timing from design to start-up can be as brief as three months, and the company prides itself as being to provide a rapid response, including initial site analysis, negotiating and filing for utility interconnection agreements and negotiating the best possible purchase power agreements with those utilities. ISI Ltd also helps clients sell their renewable energy credits on the open market at the most financially beneficial terms. Depending upon a client’s financial situation, ISI Ltd can guide them to the most appropriate financing options and assure that they receive the maximum tax credits, depreciation, continuing income, and the highest return on their investment. Our primary purpose in making this submission to the Department of Communications, Energy and Natural Resources is to ensure that the advantages of solar photovoltaic electricity are fully understood and appreciated, and that this technology will take its place among other sources of renewable energy in Ireland. The registered address of Irish Solar Innovations Ltd is No 6, Delta Retail Park, Ballysimon Road, Limerick. This submission has been prepared in the office of Environmental Management Services, Outer Courtyard, Tullynally Castle, Castlepollard, County Westmeath; and our contact details are: Telephone +353 44 966 2222 Fax +353 44 966 2223 Email [email protected]




2.2 Our People Frank Donnelly (Managing Director; based in Edenderry, County Offaly) has been involved in building and construction for many years, and his recent contracts include the design and construction of three large-scale solar farms in England and Wales. This work was carried out by the Weform Group Ltd., which Frank Donnelly established in 2009 as an experienced, diverse and forward-thinking construction company with targets set for todays market. The Weform Group is currently engaged in a range of construction projects in Ireland and Britain, and has recently completed the building of a waste management and sorting facility at a coastal site in Oman, Gulf States. Recently completed solar PV contracts by Weform Ltd include: 1. Lannon, Wales; 6.7MW solar farm; constructed in 17 weeks, and completed

in September 2014; 2. Barrow, England; 7.4MW solar farm; constructed in 8 weeks, and completed

in March 2015; and, 3. Scunthrope, England; 38MW; constructed in 18 weeks, and completed in

March 2015. Panny Lawrence (Consultant to ISI Ltd, based in Dubai, UAE) is a Founding Partner and currently the Managing Senior Partner of the Inception Group, an international company which has revolutionised both the process and dynamics of consulting in the area of investment banking, cutting through complexities and providing simplified, sustainable value-added to its partners and projects. The Inception Group has a proven track record in the initiation of projects in high growth industry areas, offering turn-key financial and management solutions for its clients, which include government organisations, large commercial and industrial companies, and small to medium enterprises. The Inception Group has extensive experience in solar, wind and waste management, and has placed projects across the MENA region, Africa, India, USA and Europe. Supporting global food security through sustainable management of water resources, the Inception Group is also actively engaged in projects utilizing hydroponic and aquaculture technologies. One of the Group’s aims and principal activities is the opening up new markets and the application of new technologies to facilitate the transition to renewable energy against a global backdrop of overpopulation, dwindling natural resources and dramatic climate changes. The Inception Group’s partners include global industry professionals, ranging from infrastructure and strategic investors, to some of the world’s largest private equity firms. The Inception Group facilitates negotiations across all aspects of the decision-making process; from securing government land




grants to deployment of patented technologies from large EPC’s. In appropriate cases, the Group is able to offer exclusivity to its partners for “first-to-market” rights, while exercising due diligence to provide a result that exceeds investor expectations. In recent years, the Group’s principal areas of focus have been Turkey, UAE, India, Europe and Russia; having completed the largest wind farm in the UAE which raised $850 million in funding while working with the GCC to develop a combined hydroponic and aquaculture (“Aquaponic”) plant in the region. Panny Lawrence has an extensive 15 year background and proven track record in finance and investment, having provided consultancy services to companies such as HSBC, JP Morgan and Fidelity, as well as leading teams of consultants with a turnover of USD1.2 billion. Internationally, Panny Lawrence has managed over USD1 billion of assets for business leaders, holding senior management positions in several large private consultancy firms and blue chip companies. Moving into commercial real estate projects and debt restructuring, Panny became a prominent figure in Central London where he played a major role in several high profile transactions in Mayfair, Belgravia and Knightsbridge. In the Middle East, Panny’s portfolio has diversified into projects in high-growth industry sectors, having closed deals from USD8 million to USD850 million. Jack O’Sullivan (Consultant to ISI Ltd; based in Tullynally, Castlepollard, County Westmeath) has practised as an independent environmental consultant since 1977. In 1981, he established Environmental Management Services (EMS) as one of the first environmental consultancies to begin operating in Ireland, and has built up a wealth of experience in a wide range of fields. Relevant expertise includes studies in environmental policy and strategy; eco-auditing and environmental management systems; institutional strengthening and capacity building in relation to environmental activities; development of public participation in environmental decision-making; application of EU environmental Directives; planning applications, objections, appeals and inquiries; coastal resources management; marine and freshwater pollution by oil and other substances; hazardous materials impacts; waste disposal and landfill site evaluation; environmental impact assessments, screening reports for appropriate assessment (required by the EU Habitats Directive) and reviews of industrial and infrastructure projects; ecological surveys and baseline studies; mariculture planning and development, analyses of water and wastes, and dealing with spillages of toxic substances. Legal research in the environmental area, and the provision of specialist evidence at oral hearings and High Court cases are significant parts of the consultancy’s work.




Though maintaining a broad base of work in Ireland, Jack O’Sullivan has undertaken a wide range of assignments in Britain, Middle East, Far East, Africa, and Central and Eastern European countries (Lithuania, Estonia, Russia). Russian and Lithuanian languages are supported, as well as English. Before becoming an environmental consultant, Jack O’Sullivan worked as a Science Policy Analyst with the former National Science Council (based in Dublin), as Senior Environmental Consultant with the Atkins Group (based in Epsom, England), and as a fishery officer and biologist with the Lancashire and Western Sea Fisheries Joint Committee (covering the coasts of north-west England and North Wales). John Ellis (Consultant to ISI Ltd; based mainly in England, with an office in Dubai) is an experienced veteran of the renewable energy sector, and has managed projects in the areas of solar, wind and energy from waste. His experience in more than 30 countries worldwide includes land acquisition, PPA negotiations, grid connections, feasibility studies, obtaining financial investment from equity stake holders and dealing with banks. John is particularly experienced at assembling consortia of companies to bring projects through design, construction and commissioning to the final stage of successful operation, or sale on completion.




3. THE BACKGROUND TO SOLAR PHOTOVOLTAIC ENERGY

Power generation from solar photovoltaic has long been recognised as a clean sustainable energy technology which draws upon the planet’s most plentiful and widely distributed renewable energy source – the sun. The direct conversion of sunlight (or daylight, as solar PV does not need direct sunlight) to electricity occurs without any moving parts or environmental emissions during operation. It is well proven, as photovoltaic systems have now been used for fifty years in specialised applications, and grid-connected PV systems have been in use for over twenty years. They were first mass-produced in the year 2000, when German environmentalists succeeded in obtaining government support for a programme which resulted in more than 100,000 roofs being fitted with solar PV panels. Driven by advances in technology and by increases in manufacturing scale and sophistication, the cost of solar photovoltaic energy has declined steadily since the first solar cells were manufactured, and the levelised cost7 of electricity from PV is now competitive with conventional electricity sources in an expanding list of geographic regions. Net metering and financial incentives, such as preferential feed-in tariffs for solar-generated electricity, have supported solar PV installations in many countries. With current technology, photovoltaic systems recoup the energy needed to manufacture them in 1.5 to 2.5 years in Southern and Northern Europe, respectively. Mass production has been the principal key to reducing costs and gaining competitiveness; historically, PV was an expansive technology, partly because, for a long time, its key market was extremely small and restricted to applications in space where the main criterion is weight rather than cost. Intervention by governments has been indispensable in providing the necessary impetus to get out of the vicious circle of “no market – no mass production – no market”. Government financial support was first tried in Germany and Japan for what were described as “PV roof programmes”; with the first such programme being initiated in Bonn by the German Research Ministry; it financed 2,200 PV roofs, beginning in 1989. From 1994, a similar programme was conducted by the Japanese. A new German 100,000 PV Roof Programme ran from 2000 until 2003; it was actually a 300-MW PV programme that included a “zero interest rate credit” and a 12.5%

7 The levelised cost of electricity (LCOE) is a measure which attempts to compare different

methods of electricity generation on a comparable basis. It comprises an economic assessment of the average total cost to build and operate a power-generating asset over its lifetime divided by the total power output of the asset over that lifetime. The LCOE can also be regarded as the cost at which electricity must be generated in order to break-even over the lifetime of the generating plant or installation.




subsidy. The purpose of the Feed-in-Tariff (FIT) subsequently applied was to strengthen the 100,000 PV Roof Programme and enhance its productivity. Solar PV is now, after hydro and wind power, the third most important renewable energy source in terms of globally installed capacity, with more than 100 countries using solar PV. Installations may be ground-mounted (and sometimes integrated with farming and grazing) or built into the roof or walls of a building (either building-integrated photovoltaics or simply rooftop). In 2014, worldwide installed PV capacity increased to at least 177 gigawatts (GW), sufficient to supply 1.0% of global electricity demands. Due to the exponential growth of photovoltaics, installations are rapidly approaching the 200 GW mark – about 40 times the installed capacity of 2006. China, followed by Japan and the United States, is the fastest growing market, while Germany remains the world's largest producer, with solar contributing about 7% to its annual domestic electricity consumption. 4. AVAILABILITY OF SOLAR IRRADIATION IN IRELAND While it is commonly believed that the Irish weather limits the potential of solar power, the amount of solar radiation in Wexford is around 78% of the level enjoyed in Madrid, and is equivalent to the levels found in most areas of Britain, a country which has successfully deployed 4,460 MW of solar electricity in the past 5 years.8 As far back as 1975, in the aftermath of the large increase in oil prices during 1973 and 1974, the National Science Council undertook a number of research projects on renewable energy sources, one of which examined solar energy. The project report, written by Eamon Lalor9, concluded that the amount of available solar energy in Ireland was, on a per-head-of-population basis, the same as in France. A surprising conclusion perhaps, but the author of this submission remembers clearly the results obtained by Eamon Lawlor, and the unfortunate fact that when oil prices stabilised, the research project was terminated, and the proposed research programme was never carried out. More recently, a report by IBM and the City of Dublin Energy Management Agency (CODEMA) pointed out that “the amount of daylight, or the solar irradiance, Dublin receives is approximately the same as that received in Leipzig, Germany, home of

8 Submission by the Irish Solar Energy Association to the Consultation on the Green Paper on

Energy Policy in Ireland, 31 July 2014. Available from http://irishsolarenergy.org/wp-content/uploads/2014/09/ISEA-Green-Paper-on-Energy-Policy-in-Ireland.pdf

9 Lalor, Eamon, 1975. Solar Energy for Ireland: a Preliminary Analysis of the Basic Data with Tentative Proposals for a Programme of Research and Development : Report to the National Science Council. Dublin : National Science Council; Government Publications Sale Office, 1975.




one of the world’s largest solar electricity plants, Waldpolenz Solar Park.”10 The report also concluded that “Solar PV energy is a viable power strategy due to its scalability, its easy deployment and the abundant availability of solar radiation.” The map in Figure 4.1 shows the photovoltaic solar electricity potential in Europe, and it is clear that Ireland is not particularly disadvantaged; in fact the amount of solar irradiation (measured in kWh/m2) falling on Ireland is only slightly lower than in France, and very close to that in Germany. The south-east of the country gets more sun than the west and north-west, but the map surprisingly shows the extreme north of the country to be the least favoured.

Figure 4.1 Annual amounts of solar irradiation across Europe, measured in kWh/m2, on

optimally inclined south-oriented photovoltaic modules (left-hand scale) and the annual amounts of solar electricity generated by optimally inclined 1kW systems with a performance rating of 0.75.

10 Dublin – Smarter Cities Challenge Report. IBM Corporation, 2015.




The submission by the Irish Solar Energy Association to the public consultation on the Green Paper on Energy Policy in Ireland, to which we have referred above, also includes a map of solar irradiation across Ireland and Britain, which gives a more detailed view of the different levels of solar energy available, confirming the similarity between most of Ireland and the central and south-eastern areas of England (see Figure 4.2 below).

Figure 4.2 Annual amounts of solar irradiation on a horizontal surface, measured in

kWh/m2 , across the UK and Ireland. From Commission of the European Communities, Joint Research Centre.

This map shows that nearly all of Munster and the southern half of Leinster have better levels of solar irradiation than the northern and north-western parts of the country. Despite these differences, the ISEA report observes that in Northern Ireland, the feasibility of solar power has been demonstrated by the fact that the first planning permission for a utility-scale solar farm on the island of Ireland was




granted in Bishopscourt, County Down in early 2014. The reasons for this will become clear when we examine the different levels of support given to solar power installations by the two jurisdictions in Ireland. A presentation by Paul Dykes (SEAI) at a conference held in Johnstown Castle on 11 May 2011, provides data similar to that in Figure 4.1. He states that the average solar irradiation in Ireland is between 2.5 and 3.0 kWh/m2 per day, or 910-1100kWh/m2 per year; i.e., an area the size of a football pitch would receive the energy equivalent of 2,500 litres of oil per day, or enough energy to power a 60W light bulb continuously for 46 years! Paul Dykes, in the same presentation, shows that Ireland has only 6% less solar irradiation per unit area than Germany, but while Germany has 44% of the market share of solar energy, Ireland has less than 5% (see Figure 4.3 below). The stark contrast between the two countries forces us to ask why Ireland is lagging so far behind in the utilisation of solar energy, and it should become clear that the principal reason is the lack of Government support for PV technology in Ireland.

Figure 4.3 Comparison between amounts of solar irradiation falling on Spain, Germany

and Ireland: Spain receives 26% more solar energy per unit area than Ireland, while Germany receives only 6% more. Figure adapted from a presentation by Paul Dykes, SEAI, given at a conference held in Johnstown Castle on 11 May 2011.




5. INCREASING EFFICIENCY AND DECLINING COSTS OF

SOLAR PV Numerous attempts to cut down the costs of PV cells and modules to the point where they are both competitive and efficient have brought amazing results, mainly achieved by significantly increasing the conversion efficiency of PV materials. In order to increase the efficiency of solar cells, it is necessary to choose the semiconductor material with appropriate energy gap that matches the solar spectrum. This will enhance their electrical, optical, and structural properties. Choosing a better approach to get more effective charge collection is also necessary to increase the efficiency. There are several groups of materials that fit into different efficiency regimes. Ultrahigh-efficiency devices (η>30%) are made by using GaAs and GaInP2 semiconductors with multijunction tandem cells, and high-quality, single-crystal silicon materials are used to achieve high-efficiency cells (η>20%). The recent development of organic photovoltaic cells (OPVs) has greatly advanced power conversion efficiency from 3% to over 15%. To date, the highest reported power conversion efficiency ranges from 6.7% to 8.94% for small molecule, 8.4%–10.6% for polymer OPVs, and 7% to 15% for perovskite OPVs. Not only are these recently developed OPVs more efficient and low-cost, they are also more environmentally benign and made of raw materials from renewable renewable. According to a recent report by the Fraunhofer Institute11:

• The record lab cell efficiency is 25.6 % for mono-crystalline and 20.8 % for multi-crystalline silicon wafer-based technology. The highest lab efficiency in thin film technology is 21.0 % for CdTe and 20.5 % for CIGS solar cells.

• In the last 10 years, the efficiency of average commercial wafer-based silicon modules increased from about 12 % to 16 %. At the same time, CdTe module efficiency increased from 9 % to 13 %.

• In the laboratory, best performing modules are based on mono-crystalline silicon with about 23 % efficiency. Record efficiencies demonstrate the potential for further efficiency increases at the production level.

• In the laboratory, high concentration multi-junction solar cells achieve an efficiency of up to 46.0 % today. With concentrator technology, module efficiencies of up to 38.9 % have been reached (see Figure 5.1 below).

11 Fraunhofer Institute, 2015. Photovoltaics Report: Prepared by the Fraunhofer Institute for Solar

Energy Systems ISE with support of PSE AG. Freiburg, 26 August 2015. www.ise.fraunhofer.de




Figure 5.1 Increasing solar PV cell efficiencies year-on-year, obtained under laboratory

conditions. Figure adapted from the Fraunhofer Institute report cited above. It is worth pointing out that the high efficiency obtained from multi-junction concentrator solar cells with multiple p–n junctions made of different semiconductor materials could further increase as a result of continuing technical development. Each material's p-n junction will produce electric current in response to different wavelengths of light, and the use of multiple semiconducting materials allows the absorbance of a broader range of wavelengths, improving the cell's sunlight to electrical energy conversion efficiency. Traditional single-junction cells have a maximum theoretical efficiency of 34%. Theoretically, an infinite number of junctions would have a limiting efficiency of 86.8% under concentrated sunlight. As a result of these significant advances in technology, together with mass production of solar PV modules, their price has declined significantly over the last decade, dropping from around €1.5/kWp in 2010 to currently less than €0.6/kWp and is set to decline even further. The submission by the Irish Solar Energy Association to the Consultation on the Green Paper on Energy Policy in Ireland, cited above, states that:

“ … the costs of solar modules in Europe have fallen by 42% since 2011 from €0.96/w to €0.56/w. This contrasts heavily with energy prices in Ireland, which have increased by 27% in the same period. From a solar resource perspective, the cost reduction means that €1,000 invested in a solar project in Greece in 2011, will generate the same amount of electricity as €1,000 invested in a solar project in Athlone in 2014. Looking forward, installation costs for solar are projected to continue to fall a further 29% from €1.03/w in 2014 to €0.73/w by 2020. This will make solar a cheaper source of renewable energy than onshore wind, with grid parity expected no later than 2025”.




These price reductions in solar PV have also been noted by the Deutsche Bank in a report on the solar power industry. The report states that the bank expects solar electricity to become competitive with retail electricity in an increasing number of markets globally, due to declining solar panel costs as well as improving financing and customer acquisition costs. Unsubsidised rooftop solar electricity costs between US$0.08 and $0.13/kWh, 30-40% below retail price of electricity in many markets globally. In markets dependent on coal for electricity generation, the ratio of coal-based wholesale electricity to solar electricity cost was 7:1 four years ago. The ratio is now under 2:1 and could approach 1:1 over the next 12-18 months.12 The Deutsche Bank report also observes that the economics of solar PV energy have improved significantly due to the reduction in solar panel costs, financing costs and balance of system costs. Overall solar system costs have declined by approximately 15% compound annual growth rate over the past 8 years and the bank expects another 40% cost reduction over the next 4-5 years.

Figure 5.2 Cumulative production and the associated reduction in price of solar

photovoltaic modules. 12 Deutsche Bank Markets Research, 2015. The Solar Industry: FITT for Investors – Crossing the

Chasm; 27 February 2015.




Mass production must not be forgotten as a significant factor in helping to lower the price of solar PV. The report by the Franhofer Institute provides an illustration showing how every time the cumulative production of electricity from solar PV has double, the price went down by 19.6% (inflation adjusted €/Wp) (see Figure 5.2 above).13 Figure 5.3 below shows how the wholesale prices of 1.0Wp Chinese manufactured crystalline PV modules have declined from mid 2010 to 2014.

Figure 5.3 Wholesale prices of 1.0Wp Chinese manufactured crystalline PV modules,

from mid 2010 to 2014. From AES Europe GmbH, Clean Energy Investment; http://www.europe-solar.de/catalog/images/solar/price-trend-modules-h.jpg

Largely as a result of these economic and technical changes, the market for photovoltaics is fast growing; and the Compound Annual Growth Rate (CAGR) of PV installations was 44 % between 2000 and 201414. According to a recent Communication from the European Commission15, a large and stable market, combined with coordinated research and innovation and scaled

13 Fraunhofer Institute, 2015. Photovoltaics Report: Prepared by the Fraunhofer Institute for Solar

Energy Systems ISE with support of PSE AG. Freiburg, 26 August 2015. www.ise.fraunhofer.de 14 Fraunhofer Institute, 2015. Photovoltaics Report: Prepared by the Fraunhofer Institute for Solar

Energy Systems ISE with support of PSE AG. Freiburg, 26 August 2015. www.ise.fraunhofer.de 15 European Commission, 2015. Communication from the Commission -- Towards an Integrated

Strategic Energy Technology (SET) Plan: Accelerating the European Energy System Transformation. Brussels, 15.9.2015 C(2015) 6317 final.




up manufacturing, can achieve further cost reduction of key renewable technologies. Regional cooperation where there is common renewable energy potential can help achieve further cost reductions, in particular for:

• offshore wind energy systems, including deployment and maintenance technologies and techniques, and the associated grid systems;

• ocean energy; and,

• photovoltaic and solar thermal systems, algae and biomass residues. There is no doubt, from the information we have provided above, that solar PV materials and modules are becoming more efficient and cheaper, and that efficiencies will continue to increase, and prices will become lower. Whether a shortage of raw materials will slow down this trend is unknown, but in the immediate future the competitiveness of solar PV for electricity generation will improve, to the stage where it is now becoming less costly to generate electricity from solar PV than from other renewable resources such as wind or biomass. Nevertheless, it is our submission that in order to accelerate the uptake of PV systems in Ireland, appropriate State funding is needed in the form a Renewable Energy Feed-in Tariff (REFIT) or other financial support. Only with the assistance of such measures will Ireland be able to make use of the abundant solar energy available. 6. PLANNING AND DEVELOPMENT CONTROL ISSUES A further advantage of solar PV over other renewable sources of electricity (e.g., wind, anaerobic digestion, methane from landfills) is the rapidity with which solar can be deployed. Planning and consultation processes are significantly shorter than for other electricity generation technologies, while construction is extremely rapid, with a single team able to install 1 – 2MW of capacity per week on large scale solar farms. In addition, the modular nature of solar PV means that plant sizes can be adapted to local conditions, and capacity can be distributed over a wider area. In Ireland, there is plenty of suitable land on which to roll out large scale solar projects, particularly marginal agricultural land and cutaway bogs that are no longer suitable for peat cutting. Solar farms can also be implemented across a wide variety of platforms, such as commercial rooftops and former landfill sites. The latter could be particularly suitable, as these sites are usually free of heavy vegetative growth, they support only grasses and other small plants, grazing and tree growth is not permitted, and there are few other suitable uses available or permitted. However, care would have to be taken to ensure that the impermeable cover beneath the topsoil layer would not be damaged by the installation of ground-based PV systems.




Ground-based PV systems do not create the same visual impact as other renewable energy facilities, e.g., wind farms. The structures supporting the PV panels are relatively unobtrusive at ground level, being less than 2.5m in height, below the level of most hedgerows in Ireland, and therefore having minimal visual impact. The absence of moving parts results in an almost noise-free electricity generating plant, and the solar PV arrays are temporary structures, which may be removed after a period of around 20 to 25 years, after which the land can be restored to its original condition. Heavy foundations or large areas of concrete are not needed, and powerful cranes are not needed to place the solar arrays and supporting structures in position. Other potential sites include roofs of commercial buildings, sports facilities, and industrial plants. Obtaining planning permission for roof-mounted PV installations should not be difficult. In contrast, other renewable energy sources, particularly wind farms and anaerobic digestion facilities, have attracted significant objections, leading to delays in securing planning permission, appeals to An Bord Pleanála, and (in a number of recent cases) applications to the High Court to Judicially Review decisions by An Bord Pleanála. 7. SOLAR ENERGY INSTALLATIONS, BIODIVERSITY AND

AGRICULTURE Solar farms present an excellent opportunity to protect, and even to enhance, local biodiversity. In most solar farms, the panels are set on piles and there is minimal disturbance to the ground. The panels have no moving parts and the infrastructure typically disturbs less than 5% of the ground. The posts on which the panels are mounted take up less than 1% of the land area; and normally only 25-40% of the ground surface is over-sailed by panels. Because panels are raised above the ground on posts, more than 95% of the land utilised for solar farm development is still suitable for plant growth, and potentially for wildlife and agricultural activities such as light to moderate grazing. Following construction and commissioning, there is very little need for human activity on site, apart from occasional maintenance visits. Most sites have a lifespan of at least 20 years which is sufficient time for appropriate land management practices to yield wildlife benefits. A number of options exist for enhancing biodiversity on solar farms, including hedgerows, field margins, wild flower meadows, bird boxes and ponds. Each site is unique and there is no ‘one size fits all’ solution. Ultimately the best plans will be




those developed through engagement with the local community, the landowner and local and national conservation organisations. One possibility which offers great potential, but which needs to be examined carefully, is the use of worked-out peatlands as locations for large scale solar farms. While these areas are generally fairly level and may have few other uses, there are ecological considerations which must be taken into account. In recent years, worked-out bogs have been suggested as suitable areas for wind-farming, but such developments require construction of roads capable of accommodating heavy and lengthy transport vehicles, the creation of areas of hard-standing for use by cranes and other construction equipment, and the emplacement of large and heavy concrete bases to support the turbine towers; all of which have adverse effects on drainage and ecology. Provided that sufficient care is taken to prevent damage to the remaining peat layer, solar PV farms could relatively easily be developed on former bogs where further peat harvesting is not possible or has been discontinued for environmental reasons. The use of light construction materials and temporary surface protection could enable installation of PV solar arrays to proceed without significant ecological damage. In some locations, it may even be possible to undertake restoration of the peatland habitat during the lifetime of the solar farm, though we have no information yet about how peatland vegetation would re-grow in the shaded conditions under the solar panels. Restoration to former ecological conditions requires infilling or blocking former land drains dug to allow peat harvesting when the bog was in active use. Blocking of drains and re-wetting of the peatland to be restored is required, so that water levels will rise, to allow re-colonisation by Sphagnum. Maintenance of the solar farm under such conditions might be more difficult, but it is not inconceivable that specialised equipment would be developed to allow occasional inspection and maintenance to be carried out without causing ecological damage. 8. THE CASE FOR FINANCIALLY SUPPORTING SOLAR

PV ELECTRICITY The Republic of Ireland does not currently have a renewable energy feed-in tariff (REFIT) for solar energy. The unfortunate result of this lack of financial support is that, unlike other countries, there is not a strong business case in Ireland for generating electricity from solar PV and selling it back to the grid because the financial return is not favourable. This situation adversely impacts the type of business case that companies such as ISI Ltd can make for solar PV in Ireland. Rather than installing PV with the




intention of selling the electricity using a REFIT, the most-effective business case we can make for solar PV has to be based on local use, where all electricity produced is used by the building or site where it is generated. Grants are available to support renewable installations that include solar technology, such as those from the Sustainable Energy Authority of Ireland (SEAI), but these are unlikely to cover the full cost. However, there are significant opportunities to leverage private financial contributions via power purchase agreements (PPA) and other investment options, such as community funding. One approach that has worked well in County Tipperary is to call for tenders based on a target cost of energy per watt generated. So, rather than tender for a certain area of solar panels with a given capacity, suppliers could be asked to tender based on an expected cost in Euro per kWh of electricity produced. The tender evaluation would then apply expert advice to assess the technical solution offered. This helps the decision-making process because it allows for a more transparent assessment of long-term costs and capital expenditures. One further and very significant reason for introducing a renewable energy feed-in tariff (REFIT) or similar financial support for solar energy is to level the “playing pitch” between the Republic of Ireland and Northern Ireland. As the Department will be aware, under the Renewables Obligation Order (Northern Ireland) 2009, and the Renewables Obligation (Amendment) Order (Northern Ireland) 2014, electricity exported by producers to the local grid will provide a financial return to the producer. The Northern Ireland Renewables Obligation (NIRO) is the main policy instrument for incentivising renewable electricity generation in Northern Ireland, and is administered by the Department of Enterprise, Trade and Investment (DETI). The policy places a requirement on all electricity suppliers to provide proof to OFGEM that a portion of their energy supply comes from renewable sources. They account for this by supplying a number of Renewables Obligation Certificates (ROCs) to OFGEM each year. When a business or householder begins generating their own energy, they apply for and are issued with ROCs based on the technology they are using and the amount of energy they produce. These ROCs are tradable and are of value to the energy suppliers, meaning they can be sold for additional income. This is the key to the success of the NIRO scheme, which has boosted renewable energy generation in Northern Ireland from 4 per cent in 2005 to 14 per cent in 2012. Even though the scheme has worked well to date, it is intended that it will be terminated in 2017 if the Renewables Obligation Closure Order (Northern Ireland) 2015 is approved by the Legislative Assembly. This Statutory Instrument states that no renewables obligation certificates are to be issued under a renewables




obligation order for electricity generated after 31st March 2017. In the meantime, until the Order is approved, or fails to be approved, there is considerable uncertainty about whether or not ROCs will continue to be issued after the cut-off date of 31 March 2007. As the Department will be aware, the All-Ireland electricity market has operated since 01 November 2007 as a single electricity market (SEM), trading wholesale electricity in the Republic of Ireland and Northern Ireland on an All-Ireland basis, and managed by the Single Electricity Market Operator (SEMO). SEMO is a joint venture between EirGrid plc (the transmission system operator for the Republic of Ireland) and SONI (the System Operator for Northern Ireland), the latter being a wholly owned subsidiary of Eirgrid. We consider that it is a distortion of the market that payment for electricity exported to the grid from PV installations is available to micro-generators in Northern Ireland, while there is no similar payment available to the owners or operators of similar installations in the Republic of Ireland. It is our submission that the “playing field” should be levelled, and we see no reason why this cannot be done by collaboration between the Commission for Energy Regulation (CER) in the Republic of Ireland and the Authority for Utility Regulation in Northern Ireland (NIAUR), through the Memoranda of Understanding (MoU) signed by these agencies in August 2004 and June 2005, with the approval of both Governments. 9. PUBLIC PERCEPTION, AWARENESS RAISING AND

ACCEPTABILITY As we have seen from the widespread opposition to large-scale wind farms in many parts of Ireland, support and engagement of the community is vital for renewable energy projects to thrive, especially in rural areas. While most people have generally positive attitudes towards solar energy, many do not fully understand how it will benefit themselves, their commercial operations or their communities, or why it is worth making the investment. We strongly advocate that the Department should work with agencies such as the Sustainable Energy Agency of Ireland (SEAI), and with environmental NGOs to build awareness of the value of solar photovoltaic for electricity generation. We have mentioned in section 3 above how German environmentalists succeeded in persuading their government to support a programme which has now resulted in Germany becoming a leader in the production and installation of solar PV panels. In Ireland, the Action Plan by Friends of the Earth envisions a fossil fuel free Ireland by 2050, and two of the most relevant objectives in the plan are:




• “Increase renewable generation with a target of 100% renewable heat and electricity by 2040, and increase flexibility within these networks to accommodate variable renewable supplies; and.

• Support solar electricity equally with other renewable technologies with a feed in tariff or otherwise to ensure solar electricity generators get paid for their power”.16

Ireland has clearly a long way to go in order to catch up with Germany and other European countries, but the process will go more quickly and smoothly if a wide range of stakeholders are engaged. In seeking to develop large scale ground-based solar farms, we would suggest that the lessons learned from attempts to impose industrial-scale wind farms on rural populations must be taken into account. The Department will be acutely aware of the wide-spread and strong public protest and concerted opposition to proposals for the development of industrial wind farms in Ireland; and, while it is very likely that solar farms would not attract any such opposition, it will be important to obtain the support of local communities by means of proactive engagement and the provision of information. Land is an emotive issue, and rural communities will need to be convinced that this new land use would not be out of place in Ireland’s largely agricultural landscape, or would not be detrimental to farming in general. 10. CONCLUSIONS AND RECOMMENDATIONS Our principal conclusions and recommendations are: Technology Cost: The price of solar PV modules has declined significantly over

the last decade, dropping from around €1.5/kWp in 2010 to currently less than €0.6/kWp, and is set to decline even further.

PV Efficiency: Solar PV is become more efficient at converting ambient

daylight and sunshine into electricity, and the current level of efficiency will improve as a consequence of research being undertaken in Europe and worldwide.

Risk Reduction: Solar PV is a low-risk and low-maintenance technology which

has demonstrated consistent performance. Other European countries which have weather similar to Ireland, e.g., Germany and Britain, as well as Northern Ireland, have successfully implemented this technology.

16 Ireland needs an Energy Revolution – Friends of the Earth Action Plan, May 2015.




Energy Security: Ireland is heavily dependant on imported fossil fuels (gas, oil

and coal) for electricity generation, and this constitutes a significant risk to energy security at a time when the need to mitigate the worst effects of anthropogenic climate change are at last being taken seriously; leading to much more challenging emission reduction targets for greenhouse gases, together with the likelihood that there will be greater competition among nations for a decreasing availability of fossil fuels, as the global campaign to leave some of these “in the ground” gathers momentum. Diversification of indigenous renewable energy sources is a therefore strategic priority for Ireland, enabling the country to replace some imported energy with a balance of renewables that are not dependent on a single source.

Energy Efficiency: In addition to solar PV energy, Ireland’s energy policy and

strategy also must also embrace greater efficiency in energy use, and should encourage smart building technologies (including the proven “Passiv House” concept and standard which can equally be applied to commercial and industrial buildings), so as to reduce overall energy consumption and increase the proportion of renewable energy sources in comparison with non-renewable energy sources.

Local Energy: Photovoltaic installations are ideally suited to distributed

energy systems which allow generation and consumption to occur in the same place, or at very short distances. This approach reduces the cost of electricity transmission, which can be an issue for other renewable energy sources; especially large-scale wind farms, where the construction of new high-tension power lines has caused planning and environmental problems.

Environmental: Solar energy has low carbon dioxide and particulate emissions

per kWh generated; lower than other renewable energy sources. Solar farms have not been found to have any adverse effects on wildlife, and do not have to be located in upland areas of wildlife importance; while roof-mounted solar PV systems have no “land take” associated with them. This situation contrasts with wind farms, which require the construction of access roads, heavy foundations for the turbine towers, risk to birds, and potential adverse effects on human health.




Leadership: Ireland should seek to become a leader in the adoption of PV solar electricity; and, while the country may not hope to reach the levels of PV electricity generation achieved by Germany, there is an opportunity for the country to demonstrate leadership in renewable resources initiatives by using solar energy to promote long-term benefits for industry, commerce, and people.

Acceptability: There is an urgent need to raise public awareness of the value

and utility of PV-sourced electricity as an alternative to fossil-fuelled power stations, and to large-scale wind farms which have aroused so much hostility, planning objections, appeals and High Court cases. In other countries where PV installations are more numerous, people have expressed positive reactions to them, but it will be important to keep communities engaged and informed of the benefits and advantages that solar power will bring. Doing so will help keep people engaged and their attitudes positive, especially if communities can take ownership of PV installations, perhaps through innovative community funding arrangements. It is therefore very important that the Department of Communications, Energy and Natural Resources, acting together with other departments and Agencies, should embark on a proactive awareness campaign to clearly demonstrate the benefits of solar PV energy.

Feed-in Tariff: The Department of Communications, Energy and Natural

Resources, acting together with the Commission for Energy Regulation, should as a matter of urgency, and using its influence with the Government and the Department of Finance, press for and implement a solar PV renewable energy feed-in tariff (REFIT) or similar financial support measure, which would benefit solar energy and small-scale, medium-scale and large-scale producers. This is essential to make solar PV electricity more competitive, and would help to increase the prevalence of solar PV, generating many more examples to further demonstrate the technology’s financial, social and environmental advantages.

Other Funding: We would also submit that multiple funding options for solar

PV should be explored and developed. These could include direct finance from Government or local authorities (especially where a community benefit can be demonstrated), asset-based lending, partial or full funding through an energy service company (ESCO), community and crowd-funding efforts.




N-S Integration: It is unnecessary and a distortion of the market that payment

(through the ROC system) for electricity exported to the grid from solar PV installations is available to micro-generators in Northern Ireland, while there is no similar or equivalent payment available to similar installations in the Republic of Ireland. It is our submission that the “playing field” should be levelled, and we see no reason why this cannot immediately be done by collaboration between the Commission for Energy Regulation (CER) in the Republic of Ireland and the Authority for Utility Regulation in Northern Ireland (NIAUR), through the Memoranda of Understanding (MoU) signed by these agencies in August 2004 and June 2005.

Jack O’Sullivan

On behalf of Irish Solar Innovations Limited !

ISI-006 Submission to DCENR on Solar Renewable energy, 18-Sep-15.doc

Jack O'Sullivan

Jack O'Sullivan

Jack O'Sullivan

Copy sent by email, and 2nd copy hand delivered, 18 September 2015

isi-012 complete submission to dcenr on solar renewable energy, final, 18-sep-15

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