Mr. Jim Gannon:

I thank the Chairman and members. We have submitted our presentation as a form of record and I will just put out some highlights we would like to get across. Microgeneration in Ireland and across Europe is the subject of a number of different definitions, so having a common understanding of what that means is important in the setting out of any Bill like this. The price of microgeneration has come down significantly in recent years but, despite that fact, it is still expensive when setting the euro-per-kilowatt-hour cost against the delivery of renewable electricity by larger generation types. It is widely accepted, however, that there are large societal benefits from getting communities, individuals, businesses and institutions, including schools, involved directly in the low-carbon transition. In addition to this, it is important that the Department highlighted the renewable energy directive, which mandates that self-consumers, or those jointly acting as self-consumers, are entitled to remuneration for electricity they export that would reflect market value.

In Ireland there are a number of catalysts for microgeneration deployment and it is important to bear these in mind. For example, part L of the building regulations sees approximately two thirds of new homes and a number of businesses having solar PV installed on their roofs . The SEAI has supported solar PV through Government-funded retrofit programmes for a number of years. This works through communities and through intermediaries such as Tipperary Energy Agency and others, but also through EXEED with large-scale industry. For example, across 58 sites, 1.8 MW was deployed through those programmes in 2018 alone. There is also the residential solar PV pilot that started at the end of July last year and has already seen interest of 3,000 people and deployment of 500 systems. This looks at the residential sector in regard to PV panels but also battery storage and how that may interact with electric vehicles and other aspects, including heat pumps, as time goes on. There is also the accelerated capital allowance to support businesses and there are TAMS - targeted agricultural modernisation scheme - grants for microgeneration installation in regard to pigs and poultry. It is important to have those measures in mind as we think in the round of how we collectively nudge people towards microgeneration because there are a lot of, not conflicting, but different supporting measures in play at the moment.

We undertook a Behaviour & Attitudes survey last year across Ireland in respect of microgeneration. It found that 7% of people had an intention to invest in microgeneration and the perceived value of the investment was the most important concern they had, with a societal concern second to that. Interestingly, right now, people considering that they were going to invest would prefer a grant or a tax rebate. As we look at a different method of incentivisation, how the market would propose that to someone is quite important. It is a question of how the obligated party provides that value to a customer so they will move from preferring a grant to preferring some other type of incentive effect. This is just an insight into the consumer we have.

There are a number of positive aspects to microgeneration. It addresses the energy citizen and proposes a framework to address economic barriers. A unique role is identified for community projects; community is very important and we are at the heart of that transition, with many others. It is technology agnostic and, again, we feel this is important. The flexibility around a minimum tariff and control of same is quite important to address how the market can shift. There are a number of positives in this regard.

There are a couple of elements to consider in the context of SEAI operating Ireland's energy efficiency obligation scheme, which obligates the top 18 energy supply companies in the country to engage in energy efficiency. In terms of scale, it saved, in the years 2014 to 2018, over €200 million of avoided import costs and about 750,000 tonnes of CO2, so the impact and leverage this can have is not insignificant, and is equivalent to about 140,000 homes, 250,000 cars or 300,000 head of dairy cattle.

On foot of that experience, there are a couple of specific things we think would be worth consideration by the committee in its deliberations. That strict definition of what is inside and what is outside the pot of microgeneration is quite important for everyone to understand. Supply chain capability is important. Deputy Stanley mentioned the proposed 5% target and we would see that as being quite large, not in terms of ambition and it is important to have ambition, but in terms of the supply chain being able to respond. If that is just the exported electricity, it would see maybe 1.5 million homes and 300,000 businesses at the current scale of investment deploying this type of technology. Considering the supply chain and the idea of people being able to come up that curve, we look at that target in the context of how we educate the supply chain. This comes from our experience of working with the supply chain on those skills we need and the capacity required. It would be worth considering in a little more detail.

The aspect relating to cost and equitable delivery is important in that obligated suppliers tend to divest that cost and pass it through to consumers, so how that is equitably pushed down the line is quite important. Scaling and phasing is important in that, basically, one can inadvertently induce boom and bust scenarios if one has phases of development. People rush to achieve a minimum target and then, when they achieve it, they drop sticks for a period and the industry can find it hard to flex up or flex down to that.

An important issue for the energy efficiency scheme, but which would also apply to this area, is that we would not inhibit people's ability to switch supplier. That is encoded in the consumer's ability to switch from one electricity supplier to another and it is, in fact, being reinforced in the new energy efficiency directive.

When considering a Bill like this, committee members should take care to ensure that it aligns with the other types of incentive in place for large-scale renewables and microgeneration and that, as a renewable energy directive body comes down the line, it fits within the general tramlines that are set.

We look forward to engaging with queries and supporting the committee as it continues its deliberation.