Mr. John Melvin:

The plant proposed in 2019 is broadly the same as the plant proposed in 2012, but the latter can be used in different ways. One of the key differences between 2012 and 2019 is the cost of the fuel input. In 2012, the fuel input was a much lower cost for fuel imported from the United States in a very dry state. The plant was to take wet biomass from Ireland and dry and sell it in the Irish market. Appropriately dried wood chips would be a very valuable finished product. In the 2018 application, the same plant was proposed to be used but using a different fuel input. The 2018 business plan was to use some 70% of the dried biomass output of the plant to burn in the plant itself. As this was a very valuable product, the price of the fuel input changed greatly between 2012 and 2019. In essence, whatever piece of equipment one is using, the economic justification will depend on the cost of the fuel versus the benefit of drying things. A low-cost fuel in 2012 using the particular machine the company included in the application, which was a relatively low efficiency machine, could meet the business case. It could demonstrate there was a justifiable economic use for the heat in 2012.

In 2018, however, by using the much more expensive fuel, namely, the finished product of the plant, it would not necessarily be the case that the same low efficiency machine would justify the heat load at that high a price. The same machine is used in a different way but the key difference is the cost of the fuel input. What makes economic sense with a low cost fuel does not necessarily make economic sense with a very high cost fuel. We apply highly technical legislation and the very first step is to ask what is the justification for the heat. If the fuel is very expensive, one would need a very efficient machine to make it justifiable. If the fuel is very cheap, as it was in the 2012 application, a low efficiency machine can meet the justifications. That is a key difference. It was the same machine but a very different business case.

On the question on the fact that not one planned plant has become operational, there would be a relatively small number of planned plants. They take a long time to build, perhaps four, five or six years. There is one other very large planned plant that is tied up with a gas importation terminal and there are other elements behind the particular delay in that piece of equipment coming. It would not be unusual for the planned plant certificate to pre-date construction or operation by a number of years. We put a five-year limit on that. Five years is a reference figure in the European Union legislation that guides this whole process. Certain elements of those plants are tied in with the refit scheme. Timelines on the refit scheme also drive when some of the planned plants may commence operations.

On the data centre question, if a data centre is already in place and uses electricity, the processing of the data creates a large amount of heat, which is a by-product of data centres. This heat may be used to dry woodchip. If a HE CHP plant is built to replace this, no energy will have been saved because the data centre is still generating waste heat and rather than drying the biomass chips, someone is burning biomass elsewhere to dry the biomass chips. The first of two key steps in the EU legislation is to ask if there is useful heat and a business case for the heat process. The second key step is to ask if what is being planned makes it more efficient than the alternative. If the alternative is a data centre, it will use the same energy irrespective of whether the HE CHP plant is in place. In essence, therefore, no primary energy saving will be achieved compared with getting heat from a data centre.