Dr. Keith Sunderland:

I will start by thanking the committee for the opportunity to present today.

Research on topics concerning microgeneration is very rich. In general and in the context of smarter energy environments, there is a recognition that for low-voltage, LV, prosumers and other distributed sources such as electric vehicles to derive benefits, the challenge is network architecture flexibility. This architecture needs to be sufficiently flexible to support a market for prosumers but also sufficiently robust to accommodate the technical implications arising from their network contributions. Notwithstanding the research available, it is still very difficult to say definitively whether the measures proposed by the Bill will work for the Irish national interest.

It should be noted at the outset that in avoiding CO2 emissions there are cheaper alternatives to microgeneration. However it is appropriate for policy decisions to acknowledge microgeneration as a contributor as well as the environmental benefits created by social awareness of the technologies involved. Focus should therefore be on designing something that is economically efficient and socially equitable. With that in mind, my statement will examine some of the specifics proposed by the Bill. Further consideration will also be offered around the technical implications, the importance of information and the resolution of other barriers to the uptake of microgeneration. I have discussed the proposed Bill with colleagues and principal investigators at Technological University, TU, Dublin and my contribution to this meeting is reflective of research being undertaken at the Dublin energy lab, the electrical power research centre and the community grid project and demonstrator, cPAD, project.

First I would like to consider price arrangements. Price per kWh will be important in determining how many and what types of households will be incentivised to invest in the scheme. Our research has shown that larger households which have larger demand and are likely to have higher incomes will benefit more from this scheme. From the point of view of both economic efficiency and equity it is worth considering multiple feed-in tariffs based on the level of demand or the staged introduction of tariffs, increasing over time. There is also the potential to use smart electricity metering data to design individualised tariff regimes.

It is generally acknowledged that a lower capital cost for renewable energy systems is a requirement in making them more attractive to LV consumers. Decreases in the levelised cost of energy, LCOE, for solar photovoltaic, PV, energy are particularly reflective of advancements in systems. Ultimately any economic analysis needs to be cognisant of the changing cost environment and future subsidy opportunities. It should also be pointed out that while the Bill considers a range of microgeneration technologies, the dominant technology is still solar PV energy. Wind energy has seen technological improvements but when planning restrictions and practical limitations are considered, this form of energy harvesting is challenging and its deployment is restricted to outside areas of population density.

In the context of supplier obligations, how the percentage of microgeneration contribution is to be calculated must be carefully considered. Will it be on the basis of connected capacity, that is, the number of households and installations? Alternatively, will it be calculated in respect of the quantity of electricity generated? If it is the latter, what level of generation capacity will be considered? Will there be a time of use or seasonal consideration?

Another relevant question concerns the energy quantification or metering of the electricity produced. If the aggregated meter data reflect the electricity produced but do not account for any additional electricity produced and consumed on-site, should the supplier obligation be calculated on what the meter shows and compliance determined based on what is exported? Alternatively, should it be calculated inclusive of what was consumed, with compliance determined based on what was produced? Perhaps the latter is fairer and avoids market distortion, but this requires smart metering which measures import and export as well as on-site production.

The addition of communities in the Bill is welcomed. Communities organising themselves into energy communities to produce electricity can not only improve the return on investment through economies of scale, it will also make microgeneration more manageable for the electricity market as a whole. TU Dublin refers to such organised communities as community grids. It is imperative, however, that the combined financial net benefits to the community grid are sufficiently larger than the combined benefits that would accrue if each member was to invest individually. A mechanism should be found that values and assigns to the community grid the benefits that it brings to the electricity market.

The technical implications associated with microgeneration include system impacts and environmental benefits. The Bill has the potential for significant technical implications. The widespread deployment of embedded microgeneration could cause significant fluctuations in the demand for electricity at a national system level. This will be happening as we continue to promote large-scale generation using intermittent renewable energy technologies. This could lead to greater risks of system instability and possible power quality concerns. Work will need to be undertaken to ensure that the necessary knowledge and systems are in place to adapt to this new challenge.

However, these significant evidence-based analysis and assessment requirements also present research opportunities. They include resilience of networks to modern consumer requirements, particularly with increased proliferation of electrical vehicles; the complementarity of electric vehicles, requiring strategies to match charging demand to microgeneration support; demand-side response and management systems, including complementarity processes in which smart systems can be used to organise load and generation for effective prosumer engagement; resource appreciation and understanding, including enhanced models for solar PV and wind energy harvesting for domestic scales, where modelling of insolation patterns and cloud cover, as well as energy mapping will be needed; and network support mechanisms, including storage options and network voltage support requirements.

From an environmental perspective, the net life cycle benefits of the microgeneration technologies chosen for the support scheme should also be assessed and inappropriate technologies screened out. For example, a recent study of household-level gas-fired micro combined heat and power, micro-CHP, found that some technologies result in increased emissions when replacing conventional gas boilers. It is unclear why micro-CHP is being supported when these systems almost always use non-renewable fossil fuels. Marginal abatement cost assessments should be carried out on the preferred microgeneration technologies in order that those with reduced emissions at lowest cost are prioritised for support.

In respect of information, I note that not all microgeneration technologies are suitable for deployment in all situations. Many will significantly underperform, both economically and in terms of carbon emissions abatement, if they are not matched to the correct dwelling type and location. Careful thought matching technologies and design with end-use and siting is therefore required. This must be done in a manner that is accessible to the wider population, while at the same time informing of the technical capabilities and performance inhibitors. It is imperative that the necessary information for end user decision-making is available and widely disseminated.

Economic performance is not the only barrier to uptake of microgeneration technologies. For example, a study undertaken at the Dublin energy lab established that home owners worry about the reliability of microgeneration; are concerned about the disruption caused by fitting technologies into their dwellings; and have technology-specific concerns such as the reaction of neighbours and local residents to wind turbines. Moreover, process and management logistics are involved. The level of microgeneration advocated by the Bill raises issues concerning grid access, connectivity, logistics and competency. To connect to the network, registered electrical contractors perform what are termed "controlled works" and certification of the installation is required. While this is a technical requirement, regulation considerations and financial burdens are involved. Furthermore, the process is governed by an "inform-and-fit" connection process managed by ESB Networks. Should there be a significant proliferation of microgeneration, there will be logistical implications for the network operator to manage. These administrative issues, while not insurmountable in their own right, are relevant to the management of the technical implications that will become manifest and as such will require more stringent management processes, at least until smart meters become mainstream.

In summary, microgeneration contributes to wider environmental benefits but it is not the cheapest form of CO2 emission avoidance. Multiple feed-in tariffs based on level of demand or a staged introduction of tariffs should be considered. More consideration is warranted in respect of supplier obligations and how they are to be equitably apportioned. Community-based initiatives are welcomed in general but consideration is required to ensure net benefits are available to the community grid.

There will be a number of technical considerations with increased microgeneration proliferation and they should be conflated with current issues concerning e-mobility and demand-side management. It is imperative that relevant and accessible information is widely available and that it covers the spectrum of considerations involved. The barriers to microgeneration, including societal and logistical barriers, need further consideration, for a synergetic microgeneration scheme to be transparent and equitable. These concerns should be considered when assessing the likely success of the scheme and the likelihood of meeting policy targets. I thank the committee.