Ervia's Response to the Draft National Risk Assessment 2018 - Ervia
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Ervia’s Response to the
Draft National Risk
Assessment 2018
20th June 2018 Ervia
1Introduction to Ervia
Ervia is a commercial semi-state company with responsibility for the delivery of gas and
water infrastructure and services in Ireland, through Gas Networks Ireland and Irish
Water. It also provides dark fibre broadband infrastructure through its business Aurora
Telecom.
Gas Networks Ireland develops, operates and maintains the natural gas transmission
and distribution networks in Ireland, consisting of 13,954km of gas pipelines. Gas
Networks Ireland provides gas transportation services to all gas suppliers and shippers.
Irish Water is the national water utility responsible for providing safe, clean and
affordable water and wastewater services to 1.7 million customers in the Republic of
Ireland. Irish Water is responsible for the operation of all public water and wastewater
services.
These national gas and water utilities underpin the social and economic development of
Ireland and will play strategic roles in the transition of Ireland to a low carbon, climate
resistant and sustainable economy by 2050.
Ervia have reviewed the draft document and provided the following high level
observations:
Strategic Risks – Overview
Planning process
Recently, obtaining planning permission for large infrastructural / energy projects in
Ireland has proven to be quite difficult. To achieve decarbonisation and climate
mitigation goals, significant infrastructural projects will need to be undertaken in Ireland
over the coming years. Ervia agrees that a full and thorough planning process must take
place, but for strategic projects that will help mitigate climate change or help to mitigate
against climate change effects, support from government in terms of policy and planning
could help reduce the risk of a delayed planning process.
Section 4.3 Expectations for Public Expenditure
Over the coming years, Ervia will spend a significant amount of money on capital
projects through Irish Water. Long term strategic projects, such as the Greater Dublin
Water Supply project require years of planning and consultations. Irish Water requires
certainty on funding, on a multi-year basis to provide certainty for this project.
Section 5.1 Climate Change
Ireland must identify the least cost route to meet decarbonisation targets
as exchequer funding will be limited
“The cost of inaction exceeds the cost of action and this cost differential will rise steeply
with time”. Ervia agree that the cost of mitigating climate change is going to be
2substantial and that the least cost roadmap for each sector should be developed for
Ireland.
To minimise the financial burden on our citizens, Ireland must be prudent when
investing in climate change solutions. As a first step, Ireland should identify the least-
cost solution to meeting its 2050 decarbonisation targets. Each higher cost alternative
should only be considered, in turn, where the least-cost solution is not technically
feasible. The least-cost option should determine the long-term roadmap to climate
change mitigation.
The Energy Policy and Modelling Research Group at University College Cork (UCC) under
the leadership of Professor Brian Ó Gallachóir has built an excellent capability and
reputation in macro-economic energy modelling. In 2015 they published findings from
a study into the ‘least cost energy system to meet future energy needs in Ireland at least
cost and achieving CO2 emissions reduction of 80% below 1990 levels by 2050’. The
results show a balanced portfolio of technologies contributing to Ireland meeting its
targets i.e. no single technology dominates.
Consumers’ willingness to pay
The cost of mitigating climate change in Ireland will ultimately be borne by the citizens,
through taxation or through higher end use fuel costs. If Ireland is to achieve ambitious
decarbonisation targets it is expected that the cost of energy will rise. This emphasises
our earlier point that the least cost solution for each sector must be identified. It must
be noted that this is a significant risk when the willingness of Irish citizens to pay for
potentially abstract and long-term climate change mitigation measures is taken into
account.
Electrification is not the only solution to meet climate change obligations
Ervia notes on page 46 of the Draft National Risk Assessment 2018 it is stated that “As
Ireland electrifies vital services, such as transport and heating, which will be necessary
to meet climate change obligations…” Ervia would disagree that electrification is the
only solution, especially in urban built up areas where the gas network can be
decarbonised and utilised further. Ervia believe that Ireland needs both solutions,
decarbonised gas and decarbonised electricity and feel too much emphasis is placed on
renewable electricity when it is the gas network that provides its back up and flexibility.
Both networks complement each other and utilising both will reduce Ireland’s risks.
An alternative solution to decarbonising 1 million homes via electrification would be to
utilise Ireland’s biomethane potential as stated in the KPMG report “Decarbonising
domestic heat in Ireland” 1 , which shows decarbonising homes on or near the gas
network can be achieved at nearly one third of the cost by using biomethane when
1 http://www.ervia.ie/decarbonising-domestic-he/KPMG-Irish-Gas-Pathways-Report.pdf
3compared to electricity. This would significantly reduce emissions in the residential
sector and help mitigate the risk of climate change for Ireland.
Ireland’s gas network
Gas Networks Ireland (GNI) is responsible for the safe, reliable and efficient
transportation of Ireland’s gas demand (representing 30% of Ireland’s primary energy)
through the state-owned natural gas network. The network today consists of over
11,000 km of distribution pipelines and almost 2,500 km of transmission pipeline. The
gas network has been developed since gas was established in the late 1970’s, supplying
energy to 14 power stations, more than 26,000 multi-nationals and businesses and over
654,000 homes. GNI has demonstrated foresight and prudence in building an efficient
gas network with sufficient capacity to meet the gas demands of a modern Ireland
competing in the global economy.
Section 2: Geopolitical Risks
2.1 Departure of the UK from the EU
As the consultation document has highlighted, the risks for Ireland emerging from Brexit
have continued to intensify since last year’s National Risk Assessment was published,
primarily due to little progress being made with regard to the ‘shape’ Brexit will take,
particularly in relation to the UK’s future trade relationship with the EU and the border
issue in Ireland.
From an energy perspective, Ireland and the UK are heavily interconnected. Ireland is
connected to Great Britain through two subsea interconnector gas pipelines. Great
Britain is one of the most liquid and transparent natural gas markets in the world and
has a diverse range of natural gas sources from indigenous production to Liquefied
Natural Gas (LNG) and subsea interconnector pipelines to Europe, i.e. Belgium, the
Netherlands and Norway. Ireland’s two sub-sea gas interconnectors transport natural
gas from Scotland to Ireland. The interconnector system is made up of an onshore
system in Scotland and two high pressure gas interconnectors that come to shore just
north of Dublin. The interconnector system has transported up to 93% of Ireland’s
natural gas demand, prior to gas flowing from the Corrib gas field. The close proximity
of the subsea Interconnectors to Dublin ensures increased security of supply and a high
level of system capacity in the area. Northern Ireland (NI) owns and operates a pipeline
that is connected to the onshore Scotland section of the Irish interconnector system and
relies heavily on this connection for its supply of natural gas. In addition, NI has a
pipeline of over 150km in length that runs from Dublin into the North which provides
security of supply as an alternative route for gas to NI. The Isle of Man (IOM) is also
supplied natural gas via Ireland’s second sub-sea interconnector (IC2).
GNI believes that the UK’s decision to leave the EU may pose some potential risks from
an energy perspective but is committed to working with industry partners to ensure that
there will be little or no impact on the operation of the gas network, particularly in terms
4of security of supply. GNI is cooperating with parties in Europe such as GIE (Gas
Infrastructure Europe), ENTSOG (European Network of Transmission System Operators
for Gas), Eurogas etc. and has ongoing engagement with National Grid in the UK in order
to ensure that any potential impacts that Brexit might have on the operation of the Irish
gas market are identified and addressed, where possible in advance of the UK’s
departure from the EU.
Given that a vast amount of Ireland’s gas supplies are currently imported from the UK,
any imposition of tariffs on gas will inevitably increase the cost of gas to the end users.
Currently, all members of the EU Single Market benefit from having zero tariffs on
imports. If a free trade agreement is not agreed between the UK and the EU before
Brexit takes place, there will be a default to World Trade Organisation tariffs. In the case
of gas, this would infer a default tariff of between 0% and 0.7%. As both the UK and EU
are net importers of natural gas, it is unlikely either would suggest implementing a tariff.
The Ireland / UK inter-governmental gas treaty, which was signed in 1993, governs the
operation of the interconnectors. This treaty still remains in place today and will remain
in place post Brexit. In addition, NI and IOM are both connected to Great Britain’s gas
supplies via GNI infrastructure and so there is a shared interest in maintaining and
developing the interconnector infrastructure as it is beneficial to a number of parties.
GNI concurs with the view set out in the document that our interest is in the closest
possible relationship between the EU and the UK.
Section 5: Environmental Risks
In Section 5, ‘climate change’ and ‘ensuring an affordable, sustainable and diverse
energy supply’ have been identified as environmental risks. These risks are significant,
especially with an increase in extreme weather events in recent years. The seriousness
of the consequences of extreme weather events have already been seen. GNI is actively
working to do its part in reducing these risks and to mitigate against any potential
consequences.
5.1 Climate Change
GNI is cognisant of the current and potential impact of climate change on the gas
network. The implications of extreme weather conditions are carefully considered when
planning the gas network. In recent years GNI has been undertaking remedial action on
transmission pipes in floodplains to ensure that transmission pipelines in floodplain
areas are properly protected in extreme weather conditions. The existing gas pipelines
have been designed to the highest standards and have proven their resilience to
extreme weather conditions for over 40 years. Materials are specified for an operating
temperature range of -20°C to 60°C. During periods of record sub-zero temperatures in
January 2010, December 2010 and March 2018, the natural gas network demonstrated
resilience and robustness in maintaining energy security with record gas and electricity
demands.
5Winter 2017/18 had two severe weather events – extreme wind during Storm Ophelia
that resulted in widespread loss of electricity supplies and there was a prolonged cold
period with high winds during Storm Emma. No gas outages were experienced as a result
of either of these extreme events. Ireland’s natural gas network consists of buried
pipelines, which are not subject to the vulnerability of storms that can impact the
delivery of oil or the transport of electricity through overhead wires. In addition, the
routing of the gas network is designed to take account of flood plains, avoiding areas
prone to flooding wherever possible. If laying pipes in flood plains cannot be avoided,
additional precautions are taken to ensure the pipes are not adversely affected by
flooding. These include using a concrete coating as a buoyancy mechanism to prevent
pipes from lifting. Extreme rainfall in November 2009 and Winter 2015/16 saw
catchments and soils becoming increasingly saturated which led to widespread flooding.
Despite millions of euros worth of damage to other infrastructure, the gas network
remained resilient throughout, continuing to deliver gas to all customers.
5.2 Ensuring an affordable, sustainable and diverse energy supply
Security of Energy Supply - Gas
Indigenous sources of natural gas and renewable gas, combined with gas storage and
the gas interconnectors, which are linked to the competitive and highly liquid UK gas
market, provides Ireland with a secure energy future. The Corrib gas field came on
stream in 2015 with indigenous gas supply meeting 61% of demand in 2017. The Corrib
gas field will also further enhance Ireland’s security of supply for the next ten years and
make a significant contribution to generating Ireland’s electricity, heating Irish homes
and providing the energy for industry and businesses to drive the Irish economy. Ireland
is connected through two subsea interconnector pipelines to Great Britain and these
interconnectors are up to 200 km in length and can be utilised as a storage facility and
to provide backup to indigenous gas supplies. The subsea interconnectors are
connected to the British National Transmission System (NTS) at Moffat in Scotland via
an onshore pipeline in Southwest Scotland. This consists of two parallel pipelines for
approximately 30 km with a 50 km single section of pipeline. This section is currently
being paralleled or twinned.
The Twinning of the South West Scotland Onshore system, part funded by the EU, is in
the construction phase and remains on schedule for completion later this year. This
project will enhance security of supply to the island of Ireland, and bring other benefits
such as increased technical capacity at Moffat Entry Point.
In addition, there are extensive sources of biogas (agricultural, waste water etc.)
available in Ireland, with some biogas feed stocks either on or very close to the gas
network. Biogas can be upgraded to biomethane, which is a form of renewable gas, and
injected directly into the gas network. GNI is working with a renewable gas producer to
develop a Biomethane Network Entry Point and the first injection to the Network is
expected in Q4 2018. Renewable gas provides diversity of supply, enhancing energy
6security and increasing the penetration of renewables. Renewable gas also
complements natural gas and provides a self-sustaining, clean, green and reliable source
of energy. GNI believes that 20% of the gas in the network can be renewable gas by
2030. This figure is supported by independent reports by the EU Commission2 and the
SEAI3.
The development of Power to Gas, which converts excess intermittent renewable
energy, such as wind or solar energy, into gas through electrolysis and methanation will
also provide a sustainable source of renewable gas into the future.
The new Security of Gas Supply Regulation (2017/1938) came into effect on 25 October
2017. While there is no change to physical security of supply, the regulation presents a
potential compliance issue post Brexit regarding the ‘infrastructure standard’. GNI has
made the relevant stakeholders aware of this issue and will continue to liaise accordingly
to ensure where possible that no compliance issue will arise post Brexit. Furthermore,
the regulation imposes additional compliance requirements in relation to solidarity. GNI
are working with the CRU and the DCCAE on the enforcement of certain provisions in
this new regulation.
Security of Energy Supply - Transport
Transport in Ireland is 98% dependent on imported oil. There is a significant risk to the
country if we do not reduce this dependency on oil in transport. GNI is actively
supporting the development of Compressed Natural Gas (CNG) for use in transport
vehicles. The rollout of a network of CNG refuelling facilities has already commenced
with 14 fast fill CNG stations being installed across the Core TEN-T road network via a
project called the Causeway Study that is supported by the European Commission
through the CEF Transport Fund4. This will provide an alternative to diesel for trucks,
buses and vans and will reduce Ireland’s reliance on imported oil. Initially using natural
gas, CNG vehicles will see a reduction in CO2 emission of up to 22% compared with their
diesel counterparts and a huge reduction in other tailpipe emissions, such as nitrogen
oxide, sulphur dioxide and particulate matter. The first public CNG refuelling station
was commissioned in Dublin Port in June 2018.
As the production of renewable gas is scaled up and used in transport as bio-CNG, even
greater lifecycle CO2 emission reductions can be achieved. While CO2 emission
reductions contribute to climate change mitigation, the transportation of fuel through
the existing gas network will also provide fuel security in all weather conditions and
contribute to climate change adaption. Furthermore, the financial benefits for truck and
2 https://ec.europa.eu/energy/sites/ener/files/documents/ce_delft_3g84_biogas_beyond_2020_final_report.pdf
3 SEAI: Bioenergy Supply in Ireland 2015-2035, Appendix 6, Enhanced Supply
https://www.seai.ie/Publications/Renewables_Publications_/Bioenergy/Bioenergy-Supply-in-Ireland-
2015-2035.pdf
4 Connecting Europe Facility Transport Fund, https://ec.europa.eu/inea/en/connecting-europe-facility/cef-transport
7bus operators are significant with estimated fuel savings of 35% based on recent trials
carried out in Ireland.
Security of Energy Supply - Electricity
Gas is used as a fuel in the power sector and typically accounts for 40%-50% of Ireland’s
annual electricity generation5,6. Gas-fired power stations are a vital system component
to accommodate sudden changes in electricity demand or supply. Ireland has one of
the highest levels of wind penetration in Europe and requires the security and flexibility
of gas fired power plants (and the gas network) to back up this intermittent source of
renewable energy. The aforementioned severe weather conditions experienced in both
January and December 2010, demonstrated the need for significant backup to
renewable generation. In certain parts of the country the temperatures plummeted to
sub-zero during those months and energy demand, for both gas and electricity, reached
record highs. Winds were relatively light during these periods, with the low level of wind
generation requiring conventional plant to generate almost all of the high levels of
electricity required. For example, in December 2010 wind generation supplied 46 MW
of electricity, on average, over the course of a day, despite 1,400 MW of wind capacity
on the system at the time. This accounted for 1% of electricity generation. The other
99% of electricity required was generated by conventional generation, the majority of
which was from gas fired plants. GNI believes that an increase in installed wind capacity
would not reduce the high dependency on conventional generation for backup,
particularly during weather events similar to those experienced in December 2010. Any
reduction in gas fired power stations could present a risk to the electricity system as a
certain level of Ireland’s electricity will need to be generated from conventional sources
like natural gas. Ervia is working on a feasibility study for Carbon Capture and Storage
(CCS) which could help Ireland to meet its 2050 climate change targets by decarbonising
the power sector while continuing to use natural gas which provides flexibility and
stability to the electricity sector.
Climate Change, the Economy and Infrastructure
Heating and transport account for 69% of Ireland’s energy-related CO2 emissions due to
the dependence of these sectors on oil as their primary fuel source (98% in transport
and 44% in heating). Little has been done to sustainably address renewable energy in
these key energy demand areas and Ireland is currently behind on meeting its targets
for renewable energy which could result in referral to the European Court of Justice,
with significant fines and sanctions likely. The adoption of renewable gas and CNG will
reduce CO2 emissions, and assist Ireland in meeting the EU targets set out in a number
of Directives. This will help reduce or mitigate the potential fines as well as having other
5 SEAI: Energy in Ireland, Key Statistics 2015,
https://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy_in_Ireland_Key_Sta
tistics/Energy-in-Ireland-Key-Statistics-2015.pdf
6 SEAI: Energy in Ireland, 1990-2015,
http://www.seai.ie/Publications/Statistics_Publications/Energy_in_Ireland/Energy-in-Ireland-1990-
2015.pdf
8economic benefits such as job creation and rural development. Ireland’s growing
economy and population will place increased pressure on our infrastructure. However,
Ireland’s gas network has been designed with the foresight to facilitate substantial new
loads. Gas has significant environmental benefits over other heating sources such as oil.
It would be a risk to the Irish economy to ignore the benefits that Ireland’s gas
infrastructure provides. Developing and maintaining the gas network as a strategic asset
is important for Ireland from an economic and environmental perspective.
Irish Water – introduction
Irish Water (IW) is responsible for providing clean and safe water for millions of people
across Ireland. We operate and maintain water and wastewater infrastructure including
thousands of treatment plants and assets, as well as tens of thousands of kilometres of
pipe network. We provide our customers with a safe and reliable supply of drinking
water. We collect their wastewater and safely return it to the environment. In delivering
these vital services, which underpin social and economic growth for present and future
generations, we are leveraging capabilities across Ervia to transform Ireland’s ageing
and broken water network, under a single modern and efficient national utility.
Section 5.1 Climate Change
While it is recognised that “There is a necessity for realistic and frank discussion about
investments which will be needed to meet EU 2030 targets and ensure that Ireland is on
a sound pathway to decarbonisation” recognition should also be given to the level of
investment in our infrastructure required to withstand “more intense storms and
rainfall; increased likelihood and magnitude of river and coastal flooding; water
shortages in summer; … adverse impacts on water quality;” identified in the 2nd
paragraph of this section. Significant investment is required in our water services
infrastructure to increase its resilience to climate change impacts.
Section 5.3 Infrastructure constraints
This section recognises the need for sustained capital investment to meet the economic
and social needs of the country. It also recognises that Ireland’s development consent
systems need to be robust and efficient to maximise certainty and minimise delay in
converting capital to projects that deliver in order to reduce the risk of opposition from
citizens and communities to the implementation of critical infrastructure projects. This
is to be welcomed but needs to be addressed in the short term.
Housing infrastructure
Irish Water is in agreement with the Government’s statement in Section 5.3 of the
document that “…an under-supply of housing and associated affordability issues, a
tightening labour market and continued stronger than expected economic growth,
could give rise to overheating in the economy.” Irish Water has identified a strain on
the supply chain as an emerging risk with the potential to obstruct delivery of key
projects, and would like to highlight that economic overheating would have disastrous
consequences in this regard. Ervia has proposed a number of vital infrastructural
9projects, such as the Dublin Water Supply Project, which will ensure water/wastewater
services capacity does not hinder the development goals outlined in the NPF,
particularly the construction of new housing units to address the current housing
shortage. As mentioned previously, a multi-year funding commitment from the
Government would assist Irish Water in planning for major water infrastructure projects
and could help encourage new entrants into the supply chain.
6.3 Anti-Microbial Resistance
Anti-microbial resistance (AMR) is rightly identified as an increasing concern and also
referenced are increasing concerns about the role the environment may play in the
spread of clinically relevant antimicrobial resistance. However, the focus of this
document is on environmental regulators monitoring and controlling the possible
pathways responsible for the release of antimicrobials into the environment, e.g.
through water contamination and agricultural run-off and enhancing the delivery of
environmental protection from AMR. Irish Water would encourage the Government to
consider the role control at source can play to prevent, or at least reduce, the potential
for antimicrobials entering the environment through, for example, a combination of
developing alternative medications, addressing medical practice in prescribing such
medication, and/or pre-treatment of discharges from identified hotspots such as acute
hospitals and nursing homes prior to discharge to sewer.
1011
You can also read
