Micro Electricity Generation Association of Ireland
(MEGA)
Submission to Commission for Energy Regulation by invitation issued in
Consultation Paper CER/09/044 on the matter of the Treatment of Small,
Renewable and Low Carbon Generators outside
The Group Processing Approach
Submission, as requested by CER,
Submitted by email to [email protected]
Addressed To
The Commission for Energy Regulation
Paul Hogan
Electricity Distribution & Interconnection
The Exchange
Belgard Square North
Tallaght
Dublin 24
Email: [email protected]
Submission Date: April 30, 2009
Contact: Dudley Stewart C.Eng.
General Secretary,
Micro Electricity Generation Association of Ireland,
Charleville Castle, Tullamore, Co. Offaly, Ireland
Email: [email protected] Phone: 057 93 23040
Url: http://www.mega-micro.org
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Part 1 - Executive Summary
The Micro Electricity Generation Association of Ireland (MEGA) now represents the
majority of stakeholders and entrepreneurs in the emerging Micro Electricity
Generation Industry (MEG Industry).
The industry is on one hand poised to stake out an important niche in one of the
fastest growing technology markets at a global level. On the other, it’s facing into a
Power Engineering Sector which is out of date and aging, with a deficit of engineers
with relevant experience and attitude, and a surplus of engineers with a deficit in
practical power engineering skills.
There is great openness towards green energy, but a severe deficit in understanding
the “nuts and bolts” involved. Green energy is about the safe and reliable
deployment of clean power engineering innovations. At the heart of this movement is
a new emphasis on smart electricity as the central energy system displacing the
traditional liquid fuels. This means we must expect an unprecedented growth in
demand for electricity. Transport and other less traditional users will become big
electricity consumers.
The energy sector in Europe is stretching itself to reach goals and standards set for
achievement, under law, by 2020; and then again even more far reaching and
challenging standards for 2050 – ZERO CARBON ELECTRICITY.
In place is a Gate Processing Approach which has effectively stacked up, for
implementation, a massive amount of Windfarm growth. Natural gas is being put
forward as the ultimate machine to replace aging power stations and the
interconnector is being put in place to import and export electricity from the
jurisdiction.
In CER 09/044, we recognize that the CER is tackling the tricky issue of removing
impediments to the advancement of new electricity production capacity from less
intermittent sources and to increase diversity of supply. In so doing the CER is
seeking out consensus on a transparent logic on the basis of which certain
innovations and changes can take place to improve the electricity supply outlook,
having regard to the likely environmental impact and security of supply issues that
might arise. But also in mind undoubtedly is the increasing likelihood that the current
energy strategy is deeply flawed and in urgent need of repair. In all of this, MEGA
wants to be constructive and helpful. The proposed new ruling is to be generally
welcomed. There are positions taken in it that MEGA cannot agree with because they
go counter to the combined wisdom and experience of our members – we might even
go as far as calling it “Ivory Tower” thinking. Perhaps this is because our members
are taking financial risks to build a new clean energy production system within the
parameters which we hold in common. In so doing, we are “getting our hands dirty”
and are very aware of many of the practicalities that lie ahead. Ireland is going
through a time of great change. Apart from achieving economic recovery, Ireland has
serious environmental and electricity production targets to achieve. Ireland is not
alone in facing these challenges but we do have some unique assets and some
difficult liabilities to face. We recognize that the CER is trying to address some of
these in the proposed new ruling but we see new impediments to progress in the
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
Comment [DB1]:
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current document. In its current form it would serve to enshrined past mistakes into
new law.
In our response, MEGA has set out reasonable answers to some of the “options”
presented. But we are concerned that some of the fundamentals in the document are
flawed and will lead to serious problems in the future unless these are corrected now.
Our issues are essentially with the definition of public interest, also the definition of a
micro generator along with the bunching together of all renewables as one energy
category. Changes need to be made – not complex changes – just a few simple
changes. We have worked diligently to understand the issues and to present our
case coherently in the limited time available to us. We are stating that CER has to
apply better thinking to this area or a serious opportunity be lost for Irish electricity
customers and the public in general. This is a very special moment in time. There is a
serious opportunity there to put Ireland into a good position energy-wise – but it has
to be grasped or it will be lost.
It is accepted internationally that there are internal and external costs and benefits
associated with each and every different form of power generation. The external
costs and benefits typically take in the public interest aspects of any given type of
technology or power generation form, including associated employment, enterprise,
education and socio-economic gains. There may be work to be done to classify and
categorise different technologies. It is also clear that many hybrid solutions will be
involved in the future mix (Wind, Water and Biomass Hybrids etc.). These may need
to be presented better and more coherently. MEGA is ready and willing to assist in
this process. But MEGA is not ready to stand aside and will resist the CER claim that
socio-economic issues are not valid public interest parameters in the definition of
security of supply and such. The CER would also have it that Ireland alone adopt a
policy of classifying all micro generation to be “domestic” in nature and “below 6 kW,
1 phase or 11 kW, 3 Phase” in size. Why put such impediments in front of enterprise,
renewal and competitive energy generation?
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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Part 2 - Background
Smart decisions in Ireland are taken in the light of international trends, opportunities
and events. As a member state of the EU, we rely on the wisdom of the greater
community of members to guide our decisions long into the future. As a nation
competing on the international stage, our planning and direction is also formed out of
the changes taking place in the United States of America and other advanced
nations.
In setting out the response of the Micro Electricity Generation Association of Ireland
(MEGA), we feel that it is important that we give some indication of our commitment
to those two separate but ultimately merging regulatory and market environments –
the EU and the USA. As an industry we are guided and influenced by the common
effort in the EU and the standards and regulations that go with this commitment. In
looking to the future and in structuring our businesses and energy projects, we know
that much innovation will be US influenced.
In opening our response to the CER, we would like to restate the EU position below -
“EU DIRECTIVE 2001/77/EC
OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
(1) The potential for the exploitation of renewable energy sources is underused in the
Community at present. The Community recognises the need to promote renewable
energy sources as a priority measure given that their exploitation contributes to
environmental protection and sustainable development. In addition this can also
create local employment, have a positive impact on social cohesion, contribute to
security of supply and make it possible to meet Kyoto targets more quickly. It is
therefore necessary to ensure that this potential is better exploited within the
framework of the internal electricity market.
(2) The promotion of electricity produced from renewable energy sources is a high
Community priority as outlined in the White Paper on Renewable Energy Sources
(hereinafter referred to as ‘the White Paper’) for reasons of security and
diversification of energy supply, of environmental protection and of social and
economic cohesion. That was endorsed by the Council in its resolution of 8 June
1998 on renewable sources of energy (5), and by the European Parliament in its
resolution on the White Paper. (6) (3) The increased use of electricity produced from
renewable energy sources constitutes an important part of the package of measures
needed to comply with the Kyoto Protocol to the United Nations Framework
Convention.”
But also some of our members have asked us to quote some of the visionaries in the
United States who are describing the new platform on which sustainable energy
solutions must be built.
“Unprecedented Challenges and the Forces of Change
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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The electric power industry faces challenges that rival those of any period in its
history. Among these challenges, and the many debates about how to move forward,
a vision is emerging that will transform the utility industry. Utility “Smart Grid” and
advanced metering infrastructure (AMI) initiatives are introducing advanced digital
technologies into the power delivery system and end-user interface, driven by
numerous industry factors.
Consensus is growing that real-time pricing and load management, as well as
integration of behind-the-meter distributed generation and other services, are
essential to economic growth and environmental well-being.
The major drivers of this trend are well known: rising fuel prices and security
concerns, aging delivery infrastructure and human assets, rapidly increasing
deployment of renewable resources, especially solar and wind, and introduction of
new technologies such as LED lighting and high-tech electricity storage. With carbon
mitigation regulation and legislation already occurring at the state level, and likely to
occur at the national level with a new administration, the power industry will likely
face fundamental shifts in the economics of power supply and delivery. Other shifts in
the overall energy environment will add to increased power demand and delivery
complexity. One of these shifts is the
By Ralph Masiello, PhD.,
Hugo van Nispen, Robert
Wilhite, Will McNamara”
This U.S. statement above mirrors the position taken by the European Commission
and the emerging Europe-wide Smart Power Engineering Industry. This is where we
are going. Our members will play a part in getting there and, therefore, our answers
to the CER 09/044 Call For submission, though controversial and perhaps critical, is
constructed around the movement of our industry on to this new competitive ground
of operation.
MEGA is fully aware of the unprecedented economic challenges of these times. We
could all wish for massive structural changes to drive away old institutions and to
build anew in search of a better future. To wish and to have are two different things.
Pragmatically our goal therefore is to influence powerful structures to change and
evolve, to let new things happen, and to work together in search of excellence in the
new energy economy which is now unfolding.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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Contents:
Article
Title
1
2
3
Background
Executive Summary
Mega Responses
Page No.
4
5
7
9
The MEG Association (MEGA) has consulted widely and openly in drawing up our
“response” for submission to the CER. The draft response, a collaborative effort, was
approved at a meeting on April 29th 2009. The responses of a number of the existing
representative bodies (not microgen focused - but having a microgen remit) have
also been considered, and the support of these organisations has been enlisted. The
MEG Association and the Irish Farmers Association have found common cause and
have found a policy solution that will now enable joint action in pursuit of common
and jointly agreed goals.
Part 3 - THE MEGA RESPONSES
Quote CER 09 044 Draft:
“2.3 Issues with Current Process
In the operation of the current process, a number of parties have raised some issues.
These issues can be summarised thus;
There is no clear definition of the criteria by which renewable generators are
assessed once requested to be processed outside the GPA including the
definition of public interest;
There is no transparent or streamlined process whereby renewable generators or
classes of renewable generators can be assessed for connection; and
As more and more generation is applying to be connected to both the transmission
and distribution networks there is a higher likelihood of incidence of interactions due
to the connection of applicants in the GPA queue.
Question 1. Are there other issues or comments with the current process that parties
wish to bring to the Commissions attention?”
MEGA Response to CER 09044 2.3.:
Yes - there are fundamental issues which have not been raised here. It is important
to develope a cogent and transparent policy on Environmental Impact; but it is
equally important that the issue of Security of Supply be adequately described and
discussed. The legislative structure which underpins the CER authority/obligation to
take action states that “In the exercise of its functions the Commission is required,
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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under Section 9(3)(c) of the Act, to protect the interests of final customers of
electricity.” The “interests of the final customer” are not limited to the knowledge and
trust that the CER is doing a good job for them when it comes to the issue of Security
of Supply – it is not a question of trust it is a question of accessible published
information, transparency and traceability. Right now, the plan for the
accomplishment of the challenging objectives set out by the EU for 2020, is
dependent on a construction, in the future, of a massive raft of wind farm capacity –
future electricity production capacity which is not only intermittent in nature but is
also locked into the Gate Processing Approach (GPA). Much of this future capacity
may not be realised in full or on time. One question of public interest is “what is the
back-up plan?” There is a legitimate concern that the existing plan, within the GPA,
is not in fact realisable. The security of supply issue is indeed a public interest issue
but it would seem that the public is unaware of the narrow and archaic methodology
that is being applied within the GPA to supposedly assure security of supply. There
are quite naturally concerns that major power generation, transmission and smart
grid management projects might not happen on time – delays and failures which
could lead to serious, and lengthy, power interruptions.
Regarding the definition of the customer; under the various EU and Irish Government
Directives and Legislation on sustainable development, the definition of the “final
customer” extends to future customers or more specifically decisions made today
that might impact on final customers who are not yet born – the future generations. In
this context, security of supply is not just a matter of technology and Gate Processing
systems, there are also issues relating to International Agreements which might, if
not adhered to strictly, impact abruptly on the future on the supply issue.
As well as this the Gate Processing System is overburdened with valid applications,
some, if not many, of which:
1) might never get implemented.
2) others might be so speculative or outdated in design characteristics as to be
unworthy of retaining prior rights over new applicants with solutions fit for the new
times.
Of particular note would be the potential for the deployment of a whole new breed of
hybrid technologies with lesser intermittency issues (by inclusion of storage or CHP
with Wind or Hydro upstream of connection or through an Electricity Micro Grid
(local) funded by on call electricity exports (a whole raft of new solutions not included
in the Gate system but potentially blocked by it). Whereas, such systems might come
under the term “experimental” none of the elements involved might in fact be
experimental. In any case the size and number of such projects might place them in
head on collision with less commendable GPA arrangements.
The “interests of the final customer” in the question of security of supply go far
beyond the notion of trusting in the good judgement of the CER. The crisis in
regulation in the banking system has demonstrated clearly that systems and
processes operating within the CER must respect major contractual arrangements
(such as are involved in the GPA) but must also be capable of moving beyond these
arrangements in pursuit of good value, balance and security of supply while ensuring
the adherence of the electricity supply system to International Climate Change
Agreements and Targets. Many consumers are not convinced that the large number
of windfarms projected for 2020 can be, in fact, rolled out. There is evidence that
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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increasing numbers of consumers are unwilling to give credence to such large-scale
windfarm roll-outs. If targets fall short by 50% - what then?
The current illogical interpretation of the upper limit of Micro Generation (i.e. 6 KW
Single Phase – Small Scale Embedded Generation SSIG EN50438) puts into
question the CER’s credibility in terms of visible concern for the realisation of serious
changes and new growth in our electricity supply system. Growing numbers of
people are concerned that the CER is over optimistic on the current plans for security
of supply Issue – there are concerns that the CER might be ill-informed. While other
more advanced economies, with more complex and much larger electricity supply
systems, are seeking to expand the definition and promote the growth of Micro
Generation – the CER, having first erred in disallowing any reward for the export of
electricity from such generators (CER 07/208), now continues to classify micro
generators as limited to domestic supply and an upper limit of 6KW (the equivalent of
a plug ‘n play system elsewhere in Europe) – why?
This is a time to rebuild confidence in regulatory systems in Ireland, in this case the
CER- every one knows that we are facing into a time of great change. People are
legitimately concerned that our regulatory systems can help us through these times
and not trample on real new solutions. Obligations existing under the GPA system
must be recognised but not to the detriment of the public interest, particularly with
regard to security and dependability of supply and adherence to International Climate
Change Targets. Much of the planned new generation capacity under the GPA may
be late in coming on-line, much might be displaced by innovation – are we conscious
of this and exploring every avenue and tapping every resource?. It is in the public
interest to know more about the security of supply issue. It should be under constant
review within the CER, with regular public consultation and it should be openly used
as a factor for preferring applicants seeking to process schemes outside the Gate
Processing System. We cannot afford to have good solutions held back by prior
obligations to the GPA and the definition of “goodness” should not be such that it
could be granted to one project over another in any manner which could be
construed to be spurious or ultimately corrupt.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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Quote CER 09 044 Draft:
“3.0 Proposed Criteria for Assessing Public Interest
3.1.
Under Section 9(4)(a) the Commission is required to have regard for the need to
promote competition in the generation and supply of electricity to final customers.
The above legislation gives the framework for the Commission to operate within
which may be summaries as follows: the Commission may give directions to the
System Operators regarding the terms and condition under which connection offers
are issued; the Commission must act in the interest of the final customer and not
unfairly discriminate between the holders (or potential holders) of licences or
authorisations; in carrying out its functions and duties the Commission must promote
security of supply and competition and take into account the need to protect the
environment. For the avoidance of doubt, the socio-economic affects, e.g.
employment, that the development of particular types of generation may drive
is not covered by the relevant legislation and therefore cannot be used by the
Commission in formulating its decisions as it does not form part of its
legislative duties.
3.2 Public Interest Definition
At this point the Commission considers it appropriate that public interest be defined
and that certain criteria be used in assessing a generators, or class of generators,
public interest benefits. This would give potential applicants transparency on the
criteria and process used to evaluate whether an applicant can be processed outside
the GPA.
While there are benefits to a clear definition of the public interest it has to be borne in
mind that the energy market is evolving rapidly and consequently the public interest
does change over time. Also the criteria proposed here are based on the
Commissions experience to date. What will emerge in the future is unknown and
therefore the Commission, while proposing the criteria outlined below, highlights that
it would be subject to review from time to time.
The legislation outlined above gives some guidance as to what constitutes public
interest. In particular Sections 9(4) and 9(5) specifies a number of considerations that
the Commission takes into considering in the exercise of its functions and duties.
These can be summarised as:
.
Promote competition;
.
Ensure security of supply; and
.
Protect the environment/promote renewable and sustainable energy use.
Each of these will be explored in further detail below.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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3.2.1 Competition
At a commercial level electricity generating from various renewable sources would be
indistinguishable. Assuming a market segment for renewable energy does exist, then
the Commission does not believe that the market segment would be further
segmented into renewable electricity generated from wind power or renewable
electricity generated from biomass. The Commission, therefore, believes that it would
be inappropriate to use competition as a criterion for selecting projects for processing
outside the GPA given the homogeneity of the product, i.e. renewable electricity. “
CER 09044
MEGA Response to CER 09044 3.2.1
It is nonsense to say that all renewables can be bunched together, as stated above
by the CER. MEGA forecasts that in a number of year’s different renewable
technologies or innovations will be categorised, rated and prioritised into clusters with
different utility value and demand. Make the wrong choices and the consumer will
pay. It is not in the public interest to ignore the differing characteristics of different
competing renewables – value is at the centre of choice and this does include socioeconomic stability.
Quote CER 09 044 Draft:
“3.2.2 Security of Supply Diversity of Fuel Mix In determining security of electricity
supply key elements are fuel diversity and security of power fuel supplies. The more
diverse the fuel-mix in the generation system, the more secure the generation system
is to a supply shock of one fuel. In the coming years it is expected that natural gas
and wind will be the most significant sources of fuel.
In terms of fuel diversity and security of power fuel supplies, the Commission is
conscious of increasing the mix of all types of renewable generation. Therefore any
renewable technology that contributes to diversifying the fuel mix contributes to
increasing the security of supply of the system.”
Mega Response to CER 09044 3.2.3: Agreed
Quote CER 09 044 Draft:
“3.2.3 Security of Supply Predictably and Power System Support Since natural
variations of renewable energy availability do not necessarily correspond with the
also varying needs of the consumers, balancing supply and demand is a critical
issue. This will become more of an issue in the coming years as the penetration of
wind power increases. Utilising a variety of technologies that draw on a range of
renewable resources will reduce the risk of any one technology having a critical
impact on the power system balance. A diverse portfolio of renewable technologies
would move the power system toward a more secure and stable green energy
operation. The addition of less intermittent renewable technologies, ones that provide
operating reserve and potentially black start capabilities, would be supportive of the
existing grid and provide better generation demand balance capability for the power
system.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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It is proposed that any renewable generation technology that can provide primary or
secondary operating reserves be considered to be processed outside the GPA which
could offset a reduction in output by wind generation. Such facilities would need to
exceed a certain minimum export size, and it is proposed that 2 MW export capacity
and above would meet the requirement. Where such a plant can also provide black
start facilities to the system operator this will also be considered as contributing to the
public interest. “
Mega Response to CER 09044 3.2.3:
Incremental improvements to the technology (embedded automatic voltage
regulators, batteries and other elements) will improve the overall grid-friendliness of
different renewable types; but it is thro’ hybridisation that real stability and better
security of supply can be achieved. The use of tens of thousands of hybrid-electric
cars as back up supplies “on call” for use by the grid in conjunction with intermittent
renewables, has been mooted by the British Energy Regulator, for instance.
Alternatively Biofuel CHP Windpower Hybrids could run rural factories. But we can’t
agree to the CER logic as repressing “renewable technology that provides primary
and secondary reserves” by stating it is proposed that “2 MW export capacity” be the
minimum capacity of such reserves. This would seem totally incorrect in an
emerging system which is capable of using broadband communications to bunch
together (and be virtually inside) many different producers with such capability. The
CER authority should be used now to require that the system operator’s start learning
such practices and developing such capacities immediately. MEGA members are
combining to convert their intermittent energy technologies into embedded gridfriendly capacity and, even, “on call” reserve – we need to get behind and incentivise
such a move immediately. The CER could bring such reform into place through a
series of challenging steps – say starting with a minimum of 500 kW’s and moving
downwards to 50kW– the operator should be able to group these digitally, in time.
Quote CER 09 044 Draft:
“3.2.4 Environmental Benefits
Environmental benefits in this context primarily relate to the reduction of greenhouse
gas emissions and/or the reduction of energy consumption. There are a number of
renewable technologies that produce electricity with very low net production of
greenhouse gases, such as wind power and biomass. The additional benefit that
renewable technology such as biomass may bring is its predictability. Predictable
renewable generation is most likely to displace conventional generation thus
maximising the positive environmental impact.
Electricity generation which is collocated with demand, termed autoproduction,
will tend to reduce losses on the system and thereby reduce the energy
consumption on the system. Also, it is assumed final customers with on site
generation are more likely to be concerned with demand side management and
efficiency measures thereby having an overall positive effect.
3.2.5 Environment - Experimental/Research
It is in the public interest that new forms of electricity production are facilitated
where the new technology would be beneficial to the public interest in terms of
security of supply, environmental impact and/or cost.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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3.3 Conclusion
The Commission proposes to use the above criteria in the assessment of
applications for processing outside the GPA. The Commission believes that the
above criteria are consistent with the Commissions duties under the relevant
legislation given in section 3.1 above. In the next section the various types of
technology are reviewed and assessed as to how they meet the above criteria“
MEGA Response CER 09044 3.3:
There are major issues that the CER has failed to recognise under the public interest
definition. Under previous rulings and regulations very substantial reliance has been
placed on the tranquil complacency of the public, in particular the rural public, to the
placement of massive windfarms, transmission lines and substations in rural areas
with little contribution to these rural areas by way of employment, education, training
and wealth creation. Farmers throughout the country are expressing there views to
MEGA and beyond, that energy is being transported across their lands to bring
power to the cities and wealth to the big power companies. All this while every fiscal
and regulatory obstacle is being put in place to prevent the rural community
producing and selling electricity. Indeed the CER in this document has once again
sent out a loud and clear signal to rural dwellers that the CER will use it’s power
under the act to completely confuse and disturb any movement in the market that
might attract any rural dweller, be it on a part-time or fulltime basis, into the energy
production business. The Regulator (CER) has in this document stated hereinbelow
“no change in micro generation arrangements is proposed” – This is in spite of
numerous robust representations and the outright and public contradiction by
Sustainable Energy Ireland (SEI). The CER in defence says that SEI is studying this
and other matters on behalf of the CER. This doesn’t impress farmers and rural
dwellers who know that the advice provided by SEI to the CER in drafting the now
infamous CER 07/208 was completely ignored. Has something happened now to
change the behaviour of the CER? Change is needed, if we want to avoid the risk of
turbulent opposition by rural dwellers to essential new electricity plans we need to let
people into the business on a much more generous scale – but also Ireland needs
more people to take financial risks in producing clean energy. We need people to
start thinking “white oil”.
Quote CER 09 044 Draft:
“6.0 Other Issues
6.1 Impacts on Micro Generation
6.1.1 Current arrangements: Up to and including 11kW (3 phase – 6kW single)
The Commissions Decision paper Arrangements for Micro Generation
(CER/07/208) defined micro generation as generation that is rated at or below
11kW (or 0.011MW). For the purpose of this consultation the class of micro
generation, as defined previously, will continue to be treated separately to any
arrangements that are introduced for the treatment of generators outside the
GPA. Therefore no change in micro generation arrangements is proposed.
“6.1.2 Current arrangements: Greater than 11kW but less than 30kW
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Currently generators that are larger than 11kW but not greater than 30kW are
not subject to interaction studies by the system operators but are treated on
the same basis as any generator seeking connection to the network.
6.1.3 Proposed change: Extension of limit to 50kW
As part of this consultation it is proposed to change this upper limit to 50kW so
that generators up to this level would be exempt from the requirement to
undertake interaction studies to determine whether it could be processed
outside the GPA. Instead such small generation would be automatically
eligible for issuing offers outside the GPA. “ CER09044
MEGA COMMENT/COMPLAINT:
It is a fact that people applying for connections above 6 kW, 1phase experience a
totally secretive and primitive process, and that it has taken extraordinary measures
to get small numbers of these devices connected. The International Energy Agency
has asked the Irish Government to put an end to this ambiguity and take on board all
the clean energy contributors it can get.
It has set the basic parameters as:
1) Rewards [for the environmental (and other) benefits/savings and electricity
supplied]
2) Bankability [A decent rate of return and insurance regime to pass the bankability
test],
3) Access to the Grid [transparent and efficient access to the grid – access to the
grid to be treated as a very desireable outcome rather than a competitive source to
be repressed]
4) A reasonable Planning Regime.
If rural dwellers have not been conscious of these factors it is inevitable that they will
soon. Repression of this sector will lead to blockages of major infrastructural
projects and eventual supply failures. This is a matter of Public Interest. Shell
Glenamoy is a good example of what can happen if the current position prevails.
The European Commission is paving the way in describing the emerging grid system
as analogous to the Internet. There is scope for a whole raft of new players and
major opportunities for rural dwellers if the right regime is put in place. The
alternative, outlined in this CER document; is narrow, repressive and potentially
explosive – and certainly not in the public interest.
Outside Ireland governments are clambering to get green enterprise up and running
– here, every millimetre of progress could be likened to the operation of pulling teeth
– why? The answer is simple - electricity production is currently about big business,
ESB offsprings and the Regulator. If people see it like that, why should they be
tolerant of power lines crossing their fields? Why would people be supportive of giant
windfarms that don’t even create jobs? The danger is that we are nearing the UK
disease called DKDC (Don’t Know Don’t Care). We need to avoid also the
increasingly militant opposition tactics which arise out of public frustration such as
the “Shell to Sea” debacle. The CER must be well aware of the fact that we are
approaching a time when we will need to construct major dams to store water to
provide for more electricity on demand – we need people to be involved, and to
understand, the electricity production business. We don’t need a situation arising
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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which involves people looking with prejudice to stop major electricity initiatives.
MEGA says that the CER is totally incorrect in pursuing the following policy –
Policy - Quote CER 09 044 Draft:
“For the avoidance of doubt, the socio-economic affects, e.g. employment, that
the development of particular types of generation may drive is not covered by
the relevant legislation and therefore cannot be used by the Commission in
formulating its decisions as it does not form part of its legislative duties.” CER
09044
MEGA RESPONSE continued:
This policy statement above is tantamount to saying that the CER does not have a
duty “to protect the interests of final customers of electricity”. If the regulator fails to
define public interest to the point where a substantial number of the public becomes
angry and motivated to oppose infrastructure required to provide for our electricity
needs, without infringing on international law, then the regulator (CER) is setting up a
situation which is not in line with the duty of protecting “the interests of final
customers of electricity”. Socio-economic factors and employment are issues of
public interest with regard to Security of Supply. This does not mean that the public
would be supportive of employment initiatives that don’t bring value to the electricity
supply system. But it does mean that where the CER can exercise authority to open
up income generation opportunities for people, especially rural dwellers, through
smart initiatives then this would be in the public interest and consequently socioeconomics needs should be included in public interest decisions regarding security of
supply.
Training and Education is another Public Interest Issue. It is well know that engineers
and technicians are required to deliver on Security of Supply. It is also well known
that certain technologies, or sizes of technology are conducive to the training and
development of engineers and technicians – others are so bad that they actually put
young people off the idea of engineering careers. Now with the challenges that lie
ahead we find ourselves with a severe shortage of practical engineers and
technicians. MEGA insists that if the micro electricity generation industry had not
been repressed that it would have already attracted thousands of young people into
the intriguing and exciting business of generating electricity and making innovation
work – practical engineering.
We are stating categorically that the CER is incorrect in suggesting that these
matters do not lie in the CER remit - we will not relent in pursuing this issue. If
the consumer ends up paying an excessive price for electricity because all of the
relevant issues were not taken into account (some of absolute importance), then the
CER is consciously operating in disregard for the laws governing the obligations and
duties of the Energy Regulator. The issue of the External Costs and External Benefits
of certain types of energy production is not new to Power Engineering Economics.
Socio-economic factors along with education and training have always been taken
into account in such economic evaluation; it is not “different thinking”, it is standard
thinking.
The avoidance of this issue may relate to Ireland’s record of peat burning for heat
and power. A history of employment protectionism and the environmental
consequences of large scale peat harvesting should not be used as factors to distract
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
15
from the current issues which are of real concern to consumers looking forward. This
is the second time that MEGA has had to invest serious and valuable energy in the
matter of reminding the CER of the importance of comparing the Internal and
External Costs and Benefits of various energy systems. In this case large-scale wind
power and hydro requires the Irish people to call on each other to make special
allowances to allow serious new projects to move forward; to exclude the socioeconomic implications of electricity production strategy, plans, priorities and
economics is to condemn all such projects in the future to years of opposition from
disenfranchised rural and urban dwellers who have real socio economic needs.
Finally to drop the “employment question” from all future prioritisation of electricity
production is similar in some ways to deciding that electricity can be purchased by
people who have no income or that an electricity industry can survive and not suffer
power station closures or black-outs in an economic depression. Could this be true!
[Rural Reward for Rural Location – Employment - Training & Education – Social Mobilisation]
Quote CER 09 044 Draft:
“!4.1 Renewable, Low Carbon Technologies and Autoproduction
The following lists the various types of technologies and considers whether they meet
the public interest criteria outlined in Section 3.0 above.
4.1.1 Biomass Fuel
Biomass fuels are very diverse and usage of these in electricity generation can
improve waste management which gives a positive impact on the environment
contributing to the overall public interest. As detailed in the accompanying report,
CH4 is a much stronger greenhouse gas than CO2. Therefore, shifting CH4
emissions to CO2 by converting biomass to energy significantly reduces the
greenhouse warming potential of the recycled carbon associated with other means of
disposal of the biomass residues.
Biomass fuelled electricity generation technologies, whether from biomass or biogas
combustion, are typically embedded in the lower voltage distribution networks
supplying local sites and areas. From the system security and stability perspective it
can be stated that electricity generation from biomass is reliable and can be
considered as base load. Intermittency of biomass as a fuel depends on natural
cycles which are changeable on seasonal and yearly time horizons. Therefore, with
good fuel collection and transportation, electricity generation from biomass is
predictable.
Biomass has low net carbon emissions and hence would meet the public interest
criteria in terms of environmental benefit. Also the electricity produced would be
predictable in the short term and controllable. Therefore biomass generation also
meets the security of supply criterion. “
MEGA RESPONSE to CER 09044 4.1.1:
The combination of co-located wind and water power with biomass could lead to a
very exciting opportunity for grid-friendly electricity and on-call reserve in the future.
MEGA members are switching to grid-friendly thinking. REFIT Tariffs must develope
appropriately under special orders or amendments to the Public Services Obligations
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
16
(PSO) legislation to support the deployment of such technologies on time for the
consumer.
Quote CER 09 044 Draft:
“4.1.2 Combined Heat and Power (CHP)
CHP schemes are able to achieve fuel conversion efficiencies of around 90% and
there are also energy and environmental benefits to be realised. The earlier schemes
favoured natural gas but this is changing and biomass fuels are now being used. The
CHP plant is normally sized to the base heat load demand for the industrial or
commercial facility it serves. Such an approach should result in the optimum level of
heat utilisation and potentially therefore the greatest environmental benefits.
Even where the fuel is natural gas high efficiency CHP would be expected to deliver
environmental benefits in terms of the reduction of greenhouse gas emissions as it
would be expect to replace less efficient boilers, usually fired on oil. Also it is likely
that the main heat customer of a CHP plant would also have a significant electricity
demand.
The collocation of electricity production and consumption has the benefit of reducing
system losses.
CHP can also be considered a base load plant which can be predictable and
controllable by the System Operator. While the provision of operating reserve by a
CHP plant would not be its normal operating mode, the technology is generally
capable of providing it.
Therefore, in terms of the environmental and security of supply benefits the
Commission concludes that high efficiency CHP (even where the fuel source is not
renewable) would be in the public interest. “
MEGA RESPONSE to CER 09044 4.1.2:
The co-location of CHP alongside wind or water power will be complimentary to the
grid and, therefore, the consumer. This being said, it is to be expected that some
fuels should become too expensive over time. Biomass and biofuels will provide
interesting CHP options long into the future. REFIT Tariffs must develop
appropriately under special orders or amendments to the Public Services Obligations
(PSO) legislation to support the deployment of such technologies on time for the
consumer.
Quote CER 09 044 Draft:
“4.1.3 Hydro Power
Hydro storage facilities, whether in the form of pumped-hydro or hydro reservoirs,
can play a key role in providing grid operational reserve in emergency cases as well
as in cases of intermittent regime of wind power. Their advantages are the potential
for large scale electricity storage, fast response times and relatively low operating
costs. A hydro facility can replace a conventional power station or wind farm for
several hours if needed, thereby reducing the need to carry thermal generating plant
or brown energy gas fired plant as spinning reserve to support green energy plant
such as wind.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
17
Therefore, in terms of the environmental and security of supply benefits the
Commission concludes that hydro power would be in the public interest.”
MEGA RESPONSE to CER 09044 4.1.3:
MEGA agrees with the position but stresses the need for positive discrimination for
such projects as opposed to Conventional Generation and other renewables. MEGA
again is emphasising the level of social interaction and mobilisation involved in the
creation of such projects. In the construction of dams or power transmission systems,
public pathways, grazing rights, environment and other losses are involved for
individuals and the public. This is why we continuously argue for the need to factor
“people’s needs” and “people involvement” into the emerging electricity production
economy. With appropriate strategies we can mobilise hundreds of thousands of
people to be involved in the sector and to support high end results. To do this we
need to start opening up the sector and not constantly seek ways to shut it down or
shut people out. REFIT Tariffs must develop appropriately under special orders or
amendments to the Public Services Obligations (PSO) legislation to support the
deployment of such technologies on time for the consumer.
Quote CER 09 044 Draft:
“4.1.6 Autoproducers
An autoproducer is defined as a person who has entered into a connection
agreement with the DSO or TSO and generates and consumes electricity in a single
premises, or on whose behalf another person generates electricity in the single
premises, essentially for the first persons own consumption in that single
premises10. The benefits of this type of electricity generation are that production is
collocated with demand thereby reducing transmission and distribution losses and
may avoid the need to add shallow network infrastructure that would otherwise be
required. Also, consumers with on site generation are more likely to be concerned
with demand side management and efficiency measures thereby having an overall
positive effect. Where the electricity is generated from renewable or low carbon
technologies the benefits are further increased.
The Commission believes that the benefit of collocating production and demand on
its own would not bring sufficient public interest benefits to warrant priority treatment.
The addition of renewable (including wind) or low carbon technologies would merit
the processing of the connection applicant outside the GPA. Therefore the
Commission concludes that autoproduction, from renewable or low carbon
technologies, meets the public interest criteria. “ CER 09044
MEGA RESPONSE to CER 09044 4.1.6:
MEGA welcomes the CER position relating to the public interest factor of
autoproduction using renewables. However, concerns are arising that the definition of
co-location has been extended to the concept of transferring electricity production on
a corporation’s rural campus via the grid to the corporation’s urban headquarters with
high losses in transmission, high intermittency, clogging up the grid and preventing
more transparent electricity generators from gaining access to grid for essential
supply of consumer requirements and in the interest of serving genuine public
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
18
interest. MEGA is essentially serving a significant proportion of autoproduction
community. It will be watching this area to ensure fairness. MEGA is calling on the
CER to require that the system operators report openly on the Megawatt hours Distance Transported of electricity produced by autoproducers to provide the public
with a means of tracking the evolution of this sector or its abuse. It may not occur –
but if it does it could cause chaos in this constructive section of the new economy.
Quote CER 09 044 Draft:
“4.1.7 Solar Power
Solar energy is a well established renewable technology. While it is intermittent, it is
predictable. The energy density of the suns rays at Ireland’s latitude and the
conversion efficiency of photovoltaic technology mean that large areas of solar
panels would be required to generate significant electrical power. Therefore, it is
likely that solar power would be pursued in areas with on site demand and would not
require the capability to export on the grid. However for completeness the technology
would be meet the public interest criteria from a diversity of fuel mix and
environmental perspective. “
MEGA RESPONSE to CER 09044 4.1.7:
The External Benefits of Solar might be more than currently estimated. Here again is
a case where positive discrimination is required between renewable technologies.
REFIT Tariffs must develop appropriately under special orders or amendments to the
Public Services Obligations (PSO) legislation to support the deployment of such
technologies on time for the consumer. Solar is a case in point worthy of special
support and higher REFIT funded by a reformed PSO.
Quote CER 09 044 Draft:
“4.1.8 Experimental / Emerging Technologies
The Commission is conscious that whatever method is implemented to treat classes
of renewable generators outside the GPA it should encompass any new experimental
or emerging technology. Currently wave and tidal, as discussed above, could be
considered to be part of this category. This category could potentially include new
types of renewable generation, improved types of conventional generation or
technology that adds incremental benefits to current technology.
The Commission believes that it is beneficial to the public interest that experimental
and emerging technology, where it can be demonstrated to bring positive
environmental impacts and increase the security of supply, are supported and that
this in the public interest. “
MEGA RESPONSE to CER 09044 4.1.8:
To achieve the 2050 Zero Carbon Electricity requirements, serious innovation will be
required. We will see the advancement of single point of export conglomerates
providing highly useful electricity to the grid. Such island-type local community
electricity systems, with strong black start and export capability, will form the early
movement towards the EU micro grid and smart grid vision. This is too important an
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
19
area of interest to be advanced by traditional regulation. In our opinion the CER
needs to be proactive on this subject. We believe that the regulator should be looking
to make such projects happen by creating instruments which provide for the nurturing
of such systems through the difficult road to success. Again MEGA is stressing that
this could involve the development of community-based micro-grids which operate as
islands, safe for exports of pre-agreed amounts of electricity at special times of the
day or year with also the possibility of on call reserves. Such early micro grids might
involve elements of all of the generating types listed above (in fact possibly hundreds
of micro-generators balanced by more conventional CHP units, possibly biofuels,
battery and pumped storage). Such examples of rural enterprise could hold the
answer to the question of mobilising people behind essential new electricity
production strategies on a larger scale. Positive discrimination, again, may be
required to distinguish between this and other types of renewable projects. REFIT
Tariffs must develop appropriately under special orders or amendments to the Public
Services Obligations (PSO) legislation to support the deployment of such
technologies on time for the consumer.
Quote CER 09 044 Draft:
“4.2 Conclusion
In the preceding sections the Commission has outlined a number of technologies that
would meet the public interest criteria defined in Section 3.0. The Commission
acknowledges that certain technologies such as geothermal power may not be
practical due to geological reasons in Ireland. Also many of the other technologies
may have other binding constraints on their development rather than access to the
electrical network, e.g. suitable head of water for hydro power, or sufficient heat load
for CHP.
Therefore the further penetration levels of these technologies may be small and
consequential the benefits may be equally small. The corollary, that any negative
impact of process applications for connection to the network outside of the GPA
would be small, is equally true.
The Commission proposes that the above list is pre-selected for processing outside
the GPA. Any other technologies not listed here would be assessed against the
public interest criteria given in Section 3.0 above. “
MEGA RESPONSE to CER 09044 4.2:
MEGA does not agree that all of the renewables listed above can be dealt with in one
bunch; Therefore our comments are listed under each of the technologies. This being
said, REFIT Tariffs must develop appropriately under special orders or amendment
to the Public Services Obligations (PSO) legislation to support the deployment of
such technologies on time for the consumer.
Quote CER 09 044 Draft:
“5.0 Connection Options
5.1 Balancing the public interest and individuals interest
In the exercise of its functions the Commission is required, under Section 9(3)(a) of
the Act, to not discriminate unfairly between holders of licences, authorisations or
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
20
between applicants for authorisations or licences. Also in the exercise of its functions
the Commission has a duty, under Section 9(3)(c) of the Act, to act in a manner that
it considers protects the interests of final customers of electricity.
The objective of the Commission is to balance the public interest with the interest of
individual connection applicants. The Commission believes that there is a public
interest in connecting certain renewable and low carbon generators outside the GPA
as outlined above. However, there is potential for adverse impacts on generators that
would be processed within the GPA in terms of increased connection costs and
timelines. It is impossible to calculate the level or likelihood of this impact as it will
vary from connection to connection. The following sections outline a number of
options for processing connections. The options are designed to take into account
the public interest benefits, limit the adverse impacts to other connection applicants,
be practical to implement and be administratively light for the connecting party and
System Operators. “
MEGA Response to CER 09044:
MEGA agrees with the CER in principal but it is incorrect to bunch all renewables
together when considering connection. Certain renewable combinations (hybrid
biomass/wind/water etc.) can provide better utility to the grid (consumer + public
interest). In the first place there is a need to assure transparency and access to
accurate information. In the second place there should be different classes of
usefulness (value) levels (clearly defined – if not available immediately priority should
be given to the development of such a classification system) to the grid (reduced
intermittency, storage etc). Better solution (merit) should prevail in decision-making –
outdated rights (GPA) are not in the public interest. Adverse impacts on GPA
generators would not occur as the public interest would be served by the better
solution. The test should be primarily on merit.
Quote CER 09 044 Draft:
“5.2 Connection Options
The following options assume that an application to be processed outside the queue
fulfils the public interest criteria as set out above. The issue of a connection offer to
this qualifying generator would be based on one of the following proposed options.
5.2.1 Options Shallow connection
5.2.1.3 Option 3
This option is a hybrid of Options 1 and 2 using a threshold.
Generators with MEC less than or equal to 1 MW:
The proposal here is that generators with a Maximum Exporting Capacity (MEC) of
less than or equal to 1 MW would be processed outside the GPA; interactions
between the applicant and any other applicant or in the queue are not investigated or
considered.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
21
The order in the GPA queue is determined on date order. Please refer to the Group
Processing Approach papers for details. The applicant would need to be processed
according to Gate 3 or subsequent gate rules.
Generators with MEC greater than 1 MW:
The proposal here is that interaction studies would be performed for those generators
wishing to be processed outside the queue for those with an MEC of greater than
1MW. The Commission is proposing that if the result of the interaction study shows
that the applicant wishing to be processed outside of the GPA does not have an
interaction with any other applicant who is in the GPA queue ahead of it, then the
applicant should be allowed to connect. Should the result of the study show an
interaction, that is, the applicant does have an interaction, with another applicant who
is ahead in the GPA, the Commission is proposing that the applicant have the option
of effectively buying out that interaction. . “
MEGA RESPONSE to CER 09044 5.2.1:
Having weighed the balance of interests from the MEGA perspective, 5.2.1.3 Option
3 appears to represent the more sustainable solution over time.
Quote CER 09 044 Draft:
“5.2.2 Deep Transmission Reinforcements Considerations
MEGA RESPONSE to CER 09044 5.2.2:
Out of current scope for MEGA
Quote CER 09 044 Draft:
“5.2.3 Market Impacts …………………………
MEGA RESPONSE to CER 09044 5.2.3:
Out of current scope for MEGA
Quote CER 09 044 Draft:
5.3 Public Interest and Impacts on Other Applicants
The Commission has proposed allowing classes of renewable generators to be…
MEGA RESPONSE to CER 09044 5.2.1:
Having weighed the balance of interests from the MEGA perspective, 5.2.1.4 Option
4 appears to present the more sustainable solution.
Quote CER 09 044 Draft:
“6.0 Other Issues
6.1 Impacts on Micro Generation
6.1.1 Current arrangements: Up to and including 11kW
The Commissions Decision paper Arrangements for Micro Generation (CER/07/208)
defined micro generation as generation that is rated at or below 11kW (or 0.011MW).
For the purpose of this consultation the class of micro generation, as defined
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
22
previously, will continue to be treated separately to any arrangements that are
introduced for the treatment of generators outside the GPA. Therefore no change in
micro generation arrangements is proposed. “
MEGA RESPONSE to CER 09044 6.1.1:
MEGA is calling for an immediate review of CER 07/208. The Cenelec defined
category addressed in this ruling relates to a segment of micro-generation
considered to be of a “sporadic” installation type, Small Scale Embedded Generation
(SSEG) or the “Plug and Play” type micro-generator. The document is correct from a
safety point of view but only covers a small segment of microgeneration. This has
been misleading and has caused a near collapse in the Micro Electricity Generation
Industry. Micro Electricity Generation had been limited to 50 kWe internationally but
some jurisdictions are classifying micro electricity generation by the nature of the
operator just as much as the generator. This is now under review in MEGA. It is likely
that MEGA will be seeking recognition for the Micro Electricity Generation Industry as
“people or corporations who produce electricity which is exported to the grid from
renewable energy sources, or mixes of sources, the electricity export aspect not
being the primary interest of the individual or the corporation and the technology
being limited to a reasonable natural size limitation such as the original Gate
limitation of 500kW or the CER’s new natural limitation of 1MW (in line with upgrade
to the 20kV Distribution System) – the individuals or corporations are effectively
micro in comparison to mainstream power generation companies and technologies”.
This new amalgamation of individuals, and corporations, involved in the common
activity of Micro Electricity Generation, under the new MEGA definition, might prove
to be the single most important institutional innovation that might move Ireland to a
leadership niche in the Global Energy Business. At least this is the MEGA thinking on
the issue and it is our goal to see this recognised in the interest of developing a new
competitive strength in the energy industry.
Quote CER 09 044 Draft:
“6.1.2 Current arrangements: Greater than 11kW but less than 30kW
Currently generators that are larger than 11kW but not greater than 30kW are not
subject to interaction studies by the system operators but are treated on the same
basis as any generator seeking connection to the network.
MEGA RESPONSE to CER 09044 6.1.2:
This category might have been relevant under the 10kV Distribution System – it no
longer is.
Quote CER 09 044 Draft:
“6.1.3 Proposed change: Extension of limit to 50kW
As part of this consultation it is proposed to change this upper limit to 50kW so that
generators up to this level would be exempt from the requirement to undertake
interaction studies to determine whether it could be processed outside the GPA.
Instead such small generation would be automatically eligible for issuing offers
outside the GPA. “
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
23
MEGA RESPONSE to CER 09044 6.1.3:
MEGA welcomes this change but is calling for transparent, traceable, and timelined
processes to be put in place immediately. These are required to assist in rebuilding
public confidence following the recent “dark ages” for micro generation in Ireland.
MEGA is calling for a complete rethink of Micro Electricity Generation in Ireland.
There is scope to build Micro Electricity Generators (MEG) as sophisticated hybrid
systems with “always on” capability, embedded controls and voltage regulation, antiflicker, dump loads, battery storage and remote System Operator On/Off Safety
Controllers and Over-rides. The MEG Industry is confident that this will be the Third
Force in Ireland’s Energy Future – White Oil.
Quote CER 09 044 Draft:
“6.2 Proposed Process
6.2.1 DSO Proposal for Interactions
The DSO has brought forward proposals for assessing whether interactions occur if
an applicant is processed outside the queue. These new proposals follow a two
stage approach;
1. A screening interaction study is first carried out. If no interactions are found then
no further studies are carried out and the application is deemed not to interact with
any other applicant in the queue ahead of the applicant.
2. If interactions are found a more detailed interaction study is carried out.
The DSOs current approach is primarily Stage 2 above. Therefore these proposals
represent an addition to the existing process.
The screening interaction study in the first step is based upon MEC bands and that
interactions would only be looked for within these bands. The rational for these bands
is that they are based around the most likely form of connection to the network.
Assessing whether an application interacts with another application is performed by
looking at their respective MEC bands and if they belong to different bands then no
interaction is deemed to exist. “
MEGA RESPONSE to CER 09044 6.2.1:
The two stage approach represents an improvement – transparency is the main
concern.
Quote CER 09 044 Draft:
“6.3 Connection Method
Once an applicant qualifies to be processed outside the GPA the method of its
connection needs to be determined ……….
6.3.1 Group Approach or Sequential Approach
Two options are proposed, either a sequential or group approach. These options are
expanded below.
6.3.1.1 Group Approach
Under this option the group processing approach rules would be adopted. Interacting
non-GPA applicants would be studied within a subgroup and offers issued based on
the least cost technically acceptable solution (LCTA) for the whole subgroup with
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland
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shared costs on a per MW basis. This is analogous to the current group processing
approach.”
MEGA RESPONSE to CER 09 044 6.3.1:
Group approach is preferred over sequential but this is subject to there being set
timelines for decision making and full transparency on the comparative merits and
progress of all applicants. Failing this, the sequential approach would allow individual
applicants to press for early and timely decision making. Either way the issue is
about getting the processing work done, and done fairly in the public interest. In this
regard there is an urgent need for the CER to list all derogations which have been
obtained by the Systems Operators with a view to eliminating the current stop-start
problems which are currently hampering connections. It is time to eliminate these
System Operator surprises by penalising System Operators who fail to fully publish
all such derogations and non-standard practises so that Power Engineers can better
plan new installations for smooth and timely connection. Issues arising can be solved
by standard modular installations – in particular we are emphasising the VARs issue
which should not be creating the kind of mayhem that it is. We have good engineers
in Ireland – let us stop arresting the advance of this important electricity supply
system and industry – let us mobilise our good engineers, when and where problems
arise.
Micro Electricity Generation Association, Charleville Castle, Tullamore, Ireland