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28. Electricty Supply BoardMonaghan County Development Plan 2025-2031 - Pre-Draft Submission Form Deadline for submissions is Friday 7th July 2023 at 5p.m. Please read the Privacy Statement before completing this form. The Monaghan County Development Plan 2025-2031 must contain objecves and policies on a wide range of important topics. These topics are set out as headings below to assist in making a submission. A number of quesons are also posed under each of these topic headings to encourage you to think about these topics and to assist you with making suggesons on what the key issues facing County Monaghan over the future plan period are and how they can be addressed under the development plan. Please enter “N/A” in any of the comment boxes where you have no comments to make under a parcular topic. Please note, at this pre-draft stage, submissions relating to requests for zoning of land cannot be considered. It is recommended that you save your submission periodically as you enter data using the 'Save as Dra' opon at the boom of the form, especially if the submission is large or detailed. This will prevent your comments being lost in the event of a me-out or loss of connecon. Please note that submissions or observaons made to Monaghan County Council will be made available for public inspecon on the Council's website and may be redacted in line with GDPR and other legal requirements. Q1. Name of person/body submission is being made by, or on behalf of Name * Q2. Agent Details Are you an agent making a submission on behalf of the person/body stated above?* Please provide your name below * CONTACT INFORMATION * required field Electricty Supply Board Yes No Keith O'Brien Enter Full Address or Postcode Search SUBMISSION INFORMATION Below there are a list of quesons on a range of topics. These quesons should be considered as they may be helpful when draing your submission. Please note, this is not an exhausve list of topics. Space is provided below (at Q11) to insert comments relang to any other topics you consider important for consideraon in the Monaghan County Development Plan 2025-2031. Q4. Environmental Assessment and Monitoring Please provide your comments in the box below. Enter N/A if no comments.* Q5. Settlement Strategy Please provide your comments in the box below. Enter N/A if no comments.* Q6. Housing Strategy Please provide your comments in the box below. Enter N/A if no comments.* Q7. Climate Change, Environment and Heritage Please provide your comments in the box below. Enter N/A if no comments.* Q8. Economic Activity Please provide your comments in the box below. Enter N/A if no comments.* Q9. Infrastructure and Services Please provide your comments in the box below. Enter N/A if no comments.* Q10. Community Services/Facilities Please provide your comments in the box below. Enter N/A if no comments.* Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Max 2500 characters Please see attached PDF. Thanks. Q11. Are there any other topics/comments you wish to make in relation to the Monaghan County Development Plan 2025-2031? Please provide your comments in the box below. Enter N/A if no comments.* Supporting documentation By clicking the 'Submit' button you give Monaghan County Council permission to analyse and include your response in any results generated from this information. After you click submit, you will no longer be able to go back and change any of your answers. If you are having technical difficulties uploading your submission please contact devplan@monaghancoco.ie for assistance. Once you have submitted this form there will be links available on the next page to either download this form or email yourself a copy of the form. Signature * Date * Max 2500 characters Please see attached PDF. Thanks. Please upload any supporting documentation you wish to include with your submission. ESB SUB TO MONAGHAN Co. Co. ISSUES STAGE CDP 2025 - 2030_ISSUED.pdf 395.58KB Max file size per document uploaded:- 5MBs DECLARATION 07/07/2023 ESB Group Property Issues Stage – Monaghan County Development Plan Submission on behalf of ESB to the Monaghan County Development Plan 2025-2031 Pre-Draft Public Consultation Issues & Options Paper 07/07/2023 07/07/2023 Issues Stage – Monaghan County Development Plan 2 Contents 1. INTRODUCTION ........................................................................................................................... 3 Overview of ESB Strategy ...................................................................................................... 3 Generation, Transmission & Distribution ................................................................................ 3 ESB Roll-out of EV Infrastructure ........................................................................................... 4 ESB Telecoms & Telecommunications Infrastructure ............................................................ 4 2. PLANNING POLICY & PROPOSED DRAFT CDP ........................................................................ 5 Electricity Generation, Transmission & Distribution ................................................................ 5 Generation & Renewables ..................................................................................................... 7 Onshore Wind ................................................................................................................. 7 Solar ................................................................................................................................ 7 Energy Storage ............................................................................................................... 8 Hybrid Renewables ......................................................................................................... 9 Renewables-Enabling Plant ............................................................................................ 9 Telecommunications .............................................................................................................. 9 Sustainable Transport & Electric Vehicles ............................................................................ 10 Other Sustainable Transport ......................................................................................... 11 3. CONCLUSION ............................................................................................................................. 12 07/07/2023 Issues Stage – Monaghan County Development Plan 3 1. INTRODUCTION Electricity Supply Board (ESB) welcomes this opportunity to make a submission to the preparation of a County Development Plan (CDP) for County Monaghan. ESB is a landowner and employer in Monaghan with property and infrastructural assets throughout the County. As a strong, diversified, vertically integrated utility, ESB operates right across the electricity market; from generation, through transmission and distribution to supply of customers. In addition, ESB uses its networks to carry 1,545km of fibre for telecommunications to a total of 472,000 homes and to provide charging infrastructure for electric vehicles. ESB is Ireland's leading electricity utility with approximately 2.3 million customers throughout the island of Ireland. ESB broadly supports the vison included in Pre-Draft CDP Issues & Options Paper, and mitigating the impacts of, and adapting to, climate change is one of the key challenges identified in the document. There continues to be significant advancement in renewables technology and outlined below are observations regarding strategic issues that should be taken into consideration in the preparation of the Draft Monaghan CDP 2025 - 2031. Overview of ESB Strategy ESB is Ireland’s foremost energy company and the largest supplier of renewable electricity in Ireland. Through innovation, expertise and investment, ESB is leading the way in developing a modern, efficient electricity system that is capable of delivering sustainable and competitive energy supplies to customers in the ‘all-islands market’ (Republic of Ireland, Northern Ireland, England, Wales and Scotland). ESB operates a renewable energy portfolio that has a total of over 923MW of green energy generation connected to the grid. ESB is embracing new technologies that are revolutionising the energy industry, including smarter electricity networks. We are investing in sustainable energy solutions that harnesses the power of solar, wind, wave and storage to provide a cleaner future. Our objective is to develop and connect renewables to decarbonise the electricity system by 2040. ESB’s progress towards achieving carbon net-zero operations is consistent with the objectives of the National Planning Framework (NPF) and Regional Spatial & Economic Strategy (RSES) for the Northern and Western Region. Generation, Transmission & Distribution Mirroring Government objectives, by 2030 ESB will develop an additional 4 GW of new onshore and offshore wind and solar PV renewable assets to add to our 1 GW of renewables operating today. By 2030, 63% of our electricity will come from renewable sources and will be a net zero producer of electricity by 2040. ESB remains committed to completely transforming our generation portfolio, replacing old, inefficient plant with a mixture of renewables and high-efficiency gas capacity. To support the transition of the National Grid to a low-carbon future ESB is developing assets such as battery storage and flexible gas fired units that respond quickly to system demand. These will be key to facilitating large scale renewables in the future. In addition, ESB is the asset owner of the Transmission System and Distribution System and ESB Networks provides the essential service of building, managing and maintaining the electricity networks in Monaghan and throughout Ireland. ESB Networks is unique in that it is in direct contact with all electricity users. The electricity network extends to over 180,000km across the Republic of Ireland and in 2022 over 39,000 new residential and business connections were completed, along with the installation of over 1.1 million smart meters. The focus of recent investment in the network was on continuing the reinforcement of the system to facilitate the connection of new renewable electricity generation. 07/07/2023 Issues Stage – Monaghan County Development Plan 4 ESB Roll-out of EV Infrastructure ESB, has developed a network of almost 1,400 electric vehicle charge points across the Island of Ireland. In the Climate Action Plan (2023) the Irish Government has set stretching targets for EV adoption in Ireland in order to address energy demand and emissions from transport. To help meet this increase in electric vehicles, ESB, with the support of the Government’s Climate Action Fund, is rolling out high power charging hubs across the country. These hubs will be capable of quickly charging between two and eight vehicles simultaneously and will facilitate vehicles travelling longer distances across Ireland’s National and Motorway routes. ESB’s plans also include investment in green hydrogen production, storage and generation facilities by the end of this decade. A clean, zero-carbon fuel, green hydrogen will be produced from renewable energy. This is fully aligned with the EU strategy launched in 2020 on energy sector integration which prioritises a more ‘circular’ energy system with energy efficiency at its core. Greater electrification using a renewable fuel like hydrogen for end-use applications where direct electrification is not feasible (e.g., heavy goods transport, high temperature industrial heat and zero carbon dispatchable electricity generation) will play a significant role in becoming carbon-neutral by 2050. ESB Telecoms & Telecommunications Infrastructure ESB Telecoms has grown from its original function of providing a communications system for ESB to become one of Ireland’s leading independent telecommunications infrastructure providers with over 400 locations nationwide. ESB Telecoms now provides network solutions for a wide variety of mobile network operators, wireless broadband providers and public sector business activities. All sites developed by ESB Telecoms are made available to third party mobile phone and wireless broadband operators as points for co-location. Our open policy of sharing infrastructure limits the overall number of telecoms structures appearing in urban and rural landscapes. Our telecoms fibre network wrapped on our 110kV electricity network provides an extensive network throughout Ireland with international connectivity to the UK. In addition, SIRO (a joint venture between ESB and Vodafone) is bringing 100% fibre-to-the-building to 50 towns across Ireland, including Carrickmacross and Monaghan, enabling speeds of 1 Gigabit per second. SIRO will continue to accelerate this roll-out in 2023. 07/07/2023 Issues Stage – Monaghan County Development Plan 5 2. PLANNING POLICY & PROPOSED DRAFT CDP In reviewing the Strategic Issues & Options Paper, ESB has a number of observations in relation to the key issues identified that may set the framework for the future development of the County. ESB acknowledges that the process of preparing a new CDP shall be informed by the hierarchy of planning policy in Ireland. Both the National Planning Framework (NPF) and the Regional Spatial Economic Strategy (RSES) contain policies in relation to Energy Infrastructure. The Minister of Communications, Climate Action and Environment recently launched Climate Action Plan 2023. The Climate Action Plan follows the Climate Act 2021, which commits Ireland to a legally binding target of net-zero greenhouse gas emissions no later than 2050, and a reduction of 51% by 2030. These targets are a key pillar of the Programme for Government. Among the most critical measures in the Government’s Climate Action Plan is that 80% of electricity will be generated by a mix of 5 GW offshore wind, 8 GW onshore wind and 1.5 - 2.5 GW from solar PV. Energy storage systems and landside developments for offshore wind and an enhanced electricity Transmission and Distribution Grid are essential to achieving these targets. It represents a significant change for the electricity industry and ESB is committed to doing its part in supporting and delivering on the Government’s energy policy. ESB supports a review of the CDP which will include policies and objectives to support the delivery of energy infrastructure to meet future energy needs. We welcome the recognition in the Strategic Issues & Options Paper, under Infrastructure and Services that. “The supply of energy throughout the County is an important factor in the provision and location of development. Monaghan County Council will continue to work alongside key energy providers in the provision of electricity and gas, where feasible. Provision will be made within the development plan for wind energy and other renewable energy sources.” Electricity Generation, Transmission & Distribution Both the NPF and the RSES for the Northern and Western Region contain promoting policies in relation to Energy Infrastructure and ESB fully supports the reinforcement of those policies at a local level. The documents forming these plans contain key guidance in relation to the decarbonisation of the electricity sector. They set out supporting objectives for the enhancement and upgrading of existing infrastructure and the safeguarding of strategic energy corridors from encroachment by other developments that would compromise the delivery of energy networks. The new CDP 2025 – 2031 must continue to ensure that the long-term operational requirements of existing utilities are protected. The NPF National Strategic Outcome No. 8 is described in detail in the NPF and it specifically states the following in relation to energy infrastructure: “New energy systems and transmission grids will be necessary for a more distributed, more renewables focused energy generation system, harnessing both the considerable on-shore and off-shore potential from energy sources such as wind, wave and solar and connecting the richest sources of that energy.” The RSES for the Northern and Western Region outlines an overall strategy for economic development that is underpinned by the reliability of infrastructure and services including electricity generation, supply and distribution. There is a recognition in the RSES that development of the grid will enable more diverse power flows from renewable generation, strengthen resilience, security and quality of supply and importantly attract high technology industries to the Region. Regional Policy Objective, RPO 8.4 clearly sets out this position, stating. 07/07/2023 Issues Stage – Monaghan County Development Plan 6 “That reinforcements and new electricity transmission infrastructure are put in place and their provision is supported, to ensure the energy needs of future population and economic expansion within designated growth areas and across the region can be delivered in a sustainable and timely manner and that capacity is available at local and regional scale to meet future needs. Ensure that development minimises impacts on designated areas.” Existing County Development Plan recognises that new renewable generation infrastructure is required to help reach the goal to become a carbon net zero energy provider, in line with the objectives set out by the NPF. We welcome the intention in the Issues paper to make provision in the Draft Development Plan for wind and other renewable energy generation. At present the electrical load of County Monaghan is served by 3 no. 110kV Stations and by MV networks from 7 no. 38kV Stations. ESB’s 110kV Stations are located at Lisdrum, to the east of Monaghan town, at Shankill110kV Station in County Cavan, and Meath Hill 110kV Station in County Louth. There is adequate capacity in these stations to facilitate new developments in the town in the near term. At High Voltage (HV), there may be a requirement to construct new HV stations and associated networks to meet demand into the future. The Distribution System Operator (DSO) has plans to review existing network capacity and potentially develop new 110kV distribution stations in the county to facilitate the load growth in the area from new and existing businesses and also to meet government Climate Change targets. Further deep reinforcements may be required to create capacity in the county in the next 10-20 years. The exact nature of the HV station would depend on the location, nature and pace of development. Upgrades to the transmission infrastructure will ensure ongoing adequacy of regional connectivity and to facilitate the connection of renewable energy resources. In this regard, we support the inclusion of statements that support improvement, development, protection and enhancement of energy infrastructure in the Draft Development Plan. The ongoing need for curtilage management and the restriction of lands uses, which might affect the ability to consolidate and/or expand operations, is essential. Therefore, we would propose supporting statements in the Draft Plan, that seek to reinforce the existing grid including grid connections, transboundary networks into the County and the expansion into areas not adequately serviced. It is also acknowledged that parts of the county are designated under the Natura 2000 network and that the Council shall work in partnership with existing service providers to facilitate required enhancement and upgrading of existing infrastructure and networks (subject to appropriate environmental assessment and the planning process). In this regard, we note that concerns about visual, amenity, health and safety need to be mitigated through the consultation process. The NPF, RSES and Local Development Plans and the Strategic Infrastructure Act provides the necessary framework for ensuring that all necessary standards are met, and that extensive statutory and non- statutory consultation is an intrinsic part of the planning process. This ensures that there is ongoing consultation with local communities and local authorities regarding the construction of new networks. ESB supports the promotion of green renewable energy objectives and submit that they must continue to protect the County’s future capacity for the development of energy generation, processing and transmission. 07/07/2023 Issues Stage – Monaghan County Development Plan 7 Generation & Renewables In line with the Government’s response to the Climate Change Crisis, ESB is increasing renewables in our power system from 30% up to 63% by 2030 with a broader range of technologies likely to be deployed e.g., offshore wind, wave, solar etc. In this regard, ESB wish to make some observations in relation to the renewable technologies and ancillary developments as set out below. Onshore Wind According to the Climate Action Plan 2023, the share of electricity from renewable energy increased more than six-fold between 2005 and 2020 – from 7% to 39.1%. Based on SEAI analysis, February 2020 provided a record-breaking month with 56% of energy demand met by wind energy, the highest monthly total since records began. In the 12 months to end of January 2021, wind and other renewable sources, hydro, solar and biomass accounted for 36% of demand. These are encouraging trends, but further acceleration of deployment is necessary to achieve the Government’s revised targets for 2030. It is acknowledged that County Monaghan is already making a significant contribution to wind energy delivery, with a number of wind farms operating in the County and the Strategic Issues & Options Paper highlights that provision will be made within the development plan for wind energy ESB is supporting policies which promote wind energy generation. We recommend that County Council utilise the Draft Revised Wind Energy Development Guidelines 2019 (DHPLG) and the SEAI Methodology for Local Authority Renewable Energy Strategies (LARES) to inform wind energy policy in the Draft Plan. ESB support a Plan led approach through the identification of areas for wind energy development. The identified areas should be derived following a comprehensive sieve mapping analysis as outlined in the Government’s Draft Revised Wind Energy Development Guidelines (2019). In general, applications for windfarms should be assessed on a case- by-case basis, subject to viable wind speeds, environmental resources and constraints and cumulative impacts in compliance with Article 6 of the Habitats and EIA Directives. Solar Photovoltaic (PV) systems which produce electricity directly from solar radiation are becoming more widespread as their advantages become apparent and as costs fall. Solar projects will play a critical role in diversifying our renewable generation portfolio for the period out to 2030. Ireland is in a great position to take advantage of the significant reduction in the cost of solar energy over the past few years as the technology has advanced with the potential to provide a clean, diversified renewable electricity source for decades to come. Solar energy is suited to Ireland’s climate and we expect to follow the trend of other European countries and see increasing deployment of rooftop and grid scale solar energy. There is a strong correlation between wind and changing weather systems. In times of low wind there are often good solar conditions. ESB wish to highlight that solar farms have potential to be built on agricultural land, whilst also accommodating the continued use of the land for grazing or for incorporating biodiversity measures within a project. We also wish to highlight that the overall guidance on solar developments could be strengthened with the provision for extension of duration of permission. Currently, Solar PV developments can take in excess of 5 years to develop to construction phase. Securing a grid connection, relevant support tariff or corporate power purchase agreement and securing project finance has introduced significant delays for developers. Therefore, notwithstanding the provisions of Section 42 of the Planning & Development Act 2000 (as amended), it may be more appropriate 07/07/2023 Issues Stage – Monaghan County Development Plan 8 for the Planning Authority to retain the option to grant permission for a longer period if requested by the developer in appropriate circumstances. In addition, the lifetime of solar developments is extending with most technologies now suitable for a minimum of 30 years operation. Investment decisions for projects are being made on project lifetimes of up to 40 years. In this regard, ESB request that permissions are granted with a lifetime up to a maximum of 40 years. Concerns regarding the deterioration of the infrastructure can be addressed by the lodgement of a financial security in the form of a bond and the requirement to provide a Decommissioning Plan, as specified. This will ensure that the development is maintained until decommissioned and appropriately restored to agricultural use. Energy Storage Energy Storage systems such as batteries, liquid air energy storage are some of the technologies being explored that will be essential to smoothing out the natural variability that occurs in renewable energy sources and to provide electricity at times of peak demand. Utility-scale battery storage systems are being utilised to enable more efficient use of renewable energy. At present, ESB’s is installing a synchronous condenser at Moneypoint, Co. Clare which will be the first in the country and will incorporate the world's largest flywheel for grid stability. The grid stability provided by the synchronous condenser will replace and displace a fossil generator from providing these stability services, thereby lowering the carbon intensity of the electricity system. Due to the intermittency of wind energy in particular, grid stabilization technologies have an increasingly important role in a successful energy transition and this new technology is being deployed as a cost- effective and zero-carbon solution in strengthening the stability and resilience of the Irish grid. ESB is already installing Battery Energy Storage Systems (BESS) at existing facilities. BESS will operate by charging batteries using electricity and storing the energy until it is required. In addition, these batteries can stabilise the frequency of the electricity network further enabling the operation and stability of a highly renewable system. ESB has partnered with dCarbonX on the assessment and development of Irish offshore green hydrogen subsurface storage. Green Hydrogen, which is produced from renewable energy sources, offers potential for large scale seasonal storage of variable renewable energy. This enables zero carbon backup to the power system when intermittent renewables such as wind and solar are not available. Large scale Green Hydrogen production and storage could leverage the continental scale of Ireland’s renewable energy potential to enhance Ireland’s energy security and to make Ireland a net exporter of energy. There is an opportunity for Monaghan Co. Co. to support the enhancement of Ireland’s energy security with the inclusion of a specific policy supporting these new technologies, similar to the text below and in line with National and Regional policy. “Support and facilitate proposals for secure, appropriately scaled energy storage systems and infrastructure, including green hydrogen gas storage which support energy efficiency and reusable energy systems, provided such proposals accord with the principles of proper planning and sustainable development of the area.” There is scope to expand the ambition of the Draft Plan with the inclusion of specific policies supporting these new technologies. 07/07/2023 Issues Stage – Monaghan County Development Plan 9 Hybrid Renewables Hybrid renewables consists of two or more renewable energy sources used together to provide increased system efficiency as well as greater balance in energy supply, whilst optimising use of existing infrastructure. By developing hybrid renewables, plant consisting of wind, solar and battery exporting from common point of connection, but at different times, the need for transmission infrastructure associated with new generation is minimised and grid stability can be improved on. As mentioned above, repowering with hybrid renewables can grant a new lease of life to existing windfarms and other generation sites. Utilising existing infrastructure will enable accelerated connection of onshore and offshore wind to the system. By utilising hybrid connections, offshore wind projects can be efficiently delivered in a more cost-effective manner when compared to building a dedicated offshore wind grid electrical connection infrastructure. For these reasons, we would suggest that an opportunity exists for the inclusion of support for the concept of Hybrid Renewables in the Draft Plan. An Objective, containing wording as suggested below has been adopted by other local authorities. “Support and facilitate proposals for hybrid energy systems and/or co-location of renewable energy where applicable where such development has satisfactorily demonstrated that it will not have adverse impacts on the surrounding environment.” Renewables-Enabling Plant Energy security and sustainability are the main concerns in combatting climate change. Notwithstanding the Government’s aim to increase the percentage of electricity generation from renewables to 80% by 2030, the contribution from non-renewable sources will still consist of 20%. Furthermore, on dull still days or nights, almost all electricity may sometimes need to come from non- renewables generation. Given that County Monaghan has significant onshore renewables potential, the inclusion of the text below as a promotional Objective for the development of Renewable Enabling Plant will further assist in the transition to a low carbon economy. “It must also be recognised that natural gas, particularly renewable and indigenous gas, will continue to have a role to play in the transition to a low carbon economy. As such, renewable energy developments may require support from such sources in times of high energy demand.” ESB support this provision as it will be a necessary to connect additional non-renewable Plant to the grid. This efficient Plant can be applied rapidly to provide operational flexibility and the required grid support services, when needed. Typical Plant consists of fast-responding gas turbines (i.e. FlexGen Plant) to provide backup power and synchronous condensers to provide inertia & grid stability. Overall, ESB supports the promotion of energy infrastructure objectives and submit that they must continue to protect the County’s future capacity for the development of energy generating, processing, transmission and transportation infrastructure whilst encouraging the sustainable development of the County’s renewable energy resources. Telecommunications The provision of high-quality telecommunications infrastructure is recognised by Monaghan County Council as critical to the development of a knowledge economy and will help attract inward investment in hi-tech, knowledge-based industries. 07/07/2023 Issues Stage – Monaghan County Development Plan 10 ESB believes the Draft Plan should recognise that applications for telecommunications development shall be consistent with the updated guidelines (PL 07/2012) that facilitate the improved development of telecommunications infrastructure and promotion of a policy of co-location. The updated Guidelines facilitate the improved development of telecommunications infrastructure and promotion of a policy of co-location. ESB’s telecoms infrastructure in the County continues to assist in delivering enhanced communications networks through the provision of backhaul fibre and shared telecommunications towers. In addition, ESB Telecoms are working with ESB Networks to upgrade internal ESB Communications Networks to facilitate the roll-out of ESB’s ‘Smart Metering’ project. The successful delivery of ‘smart metering’ is a central component of Ireland’s plan to combat climate change through the reduction of unnecessary energy usage. Due to the extent and reach of the electricity network, additional masts may be required in some locations to ensure the delivery of ‘smart metering’ to all areas. ESB Telecoms will work within the development management standards to deliver this infrastructure. All ESB Telecoms Mast sites are open for co-location and duplication of infrastructure is reduced as a result. ESB supports the Telecommunications policy that promotes co-location. ESB encourages policies consistent with the Department Circular to allow for the improved development of telecommunications infrastructure, particularly broadband capability in the area. Sustainable Transport & Electric Vehicles With Ireland's natural advantages in terms of wind and other renewables a large proportion of the power used by electric cars will be carbon free in the future. The Irish Government’s Climate Action Plan 2023 has set stretching targets for EV adoption in Ireland to address energy demand and reduce emissions from Transport including achieving: • 845,000 passenger vehicles by 2030. • 95,000 electric vans and trucks by 2030. • Procuring 1,200 low-emissions buses for public transport in cities. • Building the EV charging network to support the growth of EVs at the rate required and develop our fast-charging infrastructure to stay ahead of demand. • New scheme for 200 on-street public charge points per year for electric vehicles The above targets demonstrate that EV’s (incl. plug-in hybrid electric vehicles PHEV’s) are central to Government targets for zero carbon emissions transportation systems. The establishment of EV infrastructure by ESB and the associated EV usage aligns with the key principles and benefits of sustainability and the National Climate Change Strategy on reduction of emissions. There are currently over 84,000 EVs and Plug-in hybrids registered on Irish roads, so while the number has improved, the pace of uptake must increase over the coming years to achieve our fleet electrification targets. ESB welcome all initiatives promoting charging infrastructure, however, it is very important to note that the EU Energy Performance of Buildings Directive calls for an increase to 20% for the number of parking spaces which should have provision for electric vehicle charging infrastructure. In preparing the new CDP, an opportunity exists to ensure availability is expanded, in line with the new directive so that the County is consistent with National and Regional Policy in relation to the provision of electric vehicle infrastructure over the lifetime of the new plan. Therefore, to ensure that the Monaghan County Development Plan increases the usage of electric vehicles to the levels required, we request that the standards as set out in Statutory Instrument No. 393/2021 – European Union (Energy Performance of Buildings) Regulations 2021. The standards 07/07/2023 Issues Stage – Monaghan County Development Plan 11 in the table below are consistent with the above Regulation and should be considered for inclusion in the Development Management Standards of the new CDP. The standards below or similar have been implemented in the latest review of Development Plans by Planning Authorities in Ireland. Promoting policies and objectives are facilitating growth in charge point infrastructure, to become a comprehensive network of public and domestic charge points, with open systems and platforms accessible to all supply companies and all types of electric cars. Development Category EV Charging Points Residential multi-unit developments both new buildings and buildings undergoing major renovations (with private car spaces including visitor car parking spaces). A minimum of 1 EV charge point space per five car parking spaces (ducting for every parking space shall also be provided) New dwellings with in-curtilage car parking. Installation of appropriate infrastructure to enable installation of recharging point for EV’s. Non-residential developments (with private car parking spaces including visitor car parking spaces with more than 10 spaces e.g., office developments) Provide at least 1 recharging point, and a minimum of 1 space per five car parking spaces should be equipped with one fully functional EV Charging Point. Developments with publicly accessible spaces (e.g., supermarket car park, cinema etc.) Provide at least 1 recharging point, and a minimum of 1 space per five car parking spaces should be equipped with one fully functional EV Charging Point. Table 1. Proposed EV Charging Point Standards Other Sustainable Transport ESB also wish to highlight that, green renewable hydrogen enables the further electrification of transport, allowing the full decarbonisation of the transport sector, as well as improved air quality as the technology replaces diesel buses and diesel HGV across Ireland. ESB has been actively engaging with Hydrogen Mobility Ireland (a partnership of businesses, public sector and academic stakeholders) to deliver a coordinated approach to this cutting-edge technology. This will ensure that Ireland can benefit from being an early starter in this solution to further decarbonise transport using renewable energy. 07/07/2023 Issues Stage – Monaghan County Development Plan 12 3. CONCLUSION Investment in infrastructure is crucial to the economic and social well-being of our country. Such investment creates jobs, stimulates economic activity and provides modern, efficient facilities to provide the services that people need including healthcare, education and community services amongst others. There is a significant multiplier effect from investment in infrastructure which means that it stimulates growth in the local economy. This investment in infrastructure is also necessary to support EU and national policy on Climate Change adaptation and mitigation. ESB, is building a truly sustainable company by investing in smart networks, renewable energy and modernising the generation portfolio. Sustainability, both within the company and in the services we provide, is integral to our corporate strategy. We are committed to reducing carbon emissions and addressing long- term concerns over future fuel supplies. ESB is implementing energy strategies that support the transition of Ireland to a low-carbon and ultimately post-carbon economy to become a competitive, resilient and sustainable region. We request that due consideration is given to the issues raised in this submission, most particularly, that the Draft County Development Plan includes clear policies in relation to: • Ensuring that the long-term operational requirements of existing utilities are protected. The importance of existing infrastructure and the associated Electricity Generation, Storage, Transmission and Distribution operations are strategic and national in nature. • The Draft Plan should maintain the planning policies which protect the County’s future capacity for the development of energy infrastructure whilst encouraging the sustainable development of renewable energy resources, including energy storage systems. This will enable ESB to develop and maintain a safe, secure, reliable, economical and efficient electricity Generation, Transmission and Distribution System with a view to ensuring that all reasonable demands for electricity are met having due regard for the environment. • Ensuring energy security during the transition to an all-green and renewables electricity sector by providing for adequate supporting energy structure which will include using the cleanest natural gas technologies aiding the integration of renewables in the shift to a sustainable energy system. • Support for hybrid connections (co-location of two or more renewable energy sources) as ESB has determined that enabling hybrid connections can expedite the connection of offshore wind. • Promoting, encouraging and facilitating the use of sustainable modes and patterns of transport, including electric vehicles, to ensure the implementation of the latest standards consistent with S.I. No. 393/2021. This will support the extension of charge point infrastructure to ensure it becomes a comprehensive network of public and domestic charge points with open systems and platforms accessible to all supply companies and all types of electric cars. If we can be of any further assistance, or if you wish to clarify any of the points raised, please do not hesitate in contacting the undersigned. Yours sincerely, ____________ Colm Cummins | Senior Planner | Engineering & Major Projects | ESB | www.esb.ie