13. Not Here Not AnywhereSubmission to Monaghan County Development Plan
Not Here Not Anywhere
This submission is made on behalf of Not Here Not Anywhere (NHNA),a nationwide,
grassroots,non-partisan group campaigning to end fossil fuel exploration and the development
of new fossil fuel infrastructure in Ireland.
To avoid the most severe impacts of climate change,global temperatures must be kept below
1.5C above pre-industrialised levels,and we will need rapid and deep action to decarbonise our
energy systems.Burning fossil fuels is the single biggest cause of climate change,and taking
climate action means developing fossil free communities in every county in Ireland.County and
city councils play a hugely important role in helping communities to transition from fossil fuels to
renewable energy,and planning is a key area of influence.This encompasses processes for
carbon-proofing major decisions,programmes and projects,including investments in transport
and energy infrastructure.We make the following recommendations regarding your new
development plan.
1.Fossil fuels and new fossil fuel infrastructure
Recommendations:
●The Monaghan County Development Plan should ensure a rapid phasing out of all fossil
fuels including gas.
●The Monaghan County Development Plan should not allow the expansion of the gas
grid.
●The Monaghan County Development Plan should ban fracked gas in its energy mix.
●Any new large scale fossil fuel infrastructure projects must be mandated to undertake
climate impact assessment to ensure they are consistent with Ireland’s fair share net
cumulative carbon dioxide (CO2)quota in line with the Paris agreement.
Impacts of Fossil Gas Projects
Research states that if we are to keep global temperature rise below 1.5°C and avoid
catastrophic climate change,fossil gas must be phased out of the energy mix in Europe by 2035
{i},discrediting claims that gas is a "transition fuel"in the transition to a decarbonised economy
{ii}{iii}.Research also states that we can’t develop any new fossil fuel infrastructure from 2019
onwards if we are to have a 64%chance of limiting temperature rise to less than 1.5°C {iv}.
Currently,69%of all gas produced in the US and imported to Europe as Liquefied Natural Gas
(LNG)is sourced through hydraulic fracturing,or fracking {v}.New LNG exports will
super-charge additional fracking,as 80%of the increased exports will come from new,i.e,
fracked,wells {vi}.Recent investigation shows that this is 40%more damaging to the climate
than coal {vii}.The lifespan of a project like LNG is at least 30 years which would increase our
dependence on dirty fossil fuels and discourage the development of renewable energy projects
{viii}.
Energy Security and LNG
New gas infrastructure is not required for energy security.A 2020 study by leading independent
consultancy,Artelys concluded that “existing EU gas infrastructure is sufficiently capable of
meeting a variety of future gas demand scenarios in the EU28,even in the event of extreme
supply disruption cases”{ix}.The European body of gas network operators,ENTSO-G,in its
2017 Security of Supply Review,found that Ireland and the UK would suffer no curtailment in
gas supply if faced with a variety of supply disruption scenarios {x}.Historically,the UK has
provided most of Ireland’s gas supply,and Ervia states that in the UK “there is ample import
capacity over and above demand”{xi}.Demand for gas in the UK has decreased by a fifth since
2004 and gas-fired electricity generation is expected to drop by 40%by 2025 {xii}.This is due to
the existing over-capacity of the EU gas grid;gas import infrastructures have import capacity
200%higher than what Europe actually imports {xiii}.
2.Data Centres
Recommendations:
●A national cap on the level of data centre demand that can be accommodated by the
grid to 2030,while meeting our renewable energy and climate emissions targets
consistent with our obligations under the Paris Agreement,must be set out in national
policy.
●New data centres must be powered entirely by onsite or new off site renewable energy.
●Existing centres should be required to transition rapidly to onsite or new off site
renewables.
●Where technically possible,heat generated from a data centre should be utilised for
district heating systems.
Eirgrid estimates that data centres could account for up to 27%of Ireland’s electricity demand
by 2028,and up to 50%of new electricity demand growth {xiv}.The Irish Academy of
Engineering predicts that data centre development will add at least 1.5 million tonnes to
Ireland’s carbon emissions by 2030,a 13%increase on current electricity sector emissions,and
will require an investment in energy generation and storage of €9 billion by 2027 {xv}.
For example,if Amazon’s eight centre project in Mulhuddart,Dublin 15,is realised,by 2026 it
would use c.4.4%per cent of the State’s entire energy capacity,the equivalent of Galway city,
but employ only 30 people post-construction,largely in facility maintenance {xvi}.The Apple
data centre proposed for Athenry,Co.Galway,would have ultimately used “over 8%of the
national capacity…,more than the daily entire usage of Dublin,and “would require 144 large
diesel generators as back-up”{xvii}.
The government has acknowledged that “data centres pose considerable challenges to the
future planning and operation of Ireland’s power system”{xviii}.These challenges include higher
electricity costs for consumers {xix}.The Danish Council on Climate Change recommended in
April 2019 that the Danish government legally binds data centre owners and developers to
contribute to the infrastructure required to supply the centres with renewable energy,such as
wind and solar farms {xx}.
Currently,many companies claim to operate data centres powered by 100%renewable energy.
However,the energy is largely sourced indirectly through Renewable Energy Certificates or
Purchase Power Agreements {xxi},which means that the energy is sourced from the grid,which
in Ireland is 69%fossil fuel-powered {xxii}.If we continue to allow companies to virtually
purchase clean energy where it is cheapest to create,while actually using and increasing
demand for dirty energy in Ireland,we allow them to profit while our real emissions continue to
rise.It is crucial therefore that data centres are powered directly by onsite renewable energy
generation such as rooftop solar farms or genuinely new offsite generation such as offshore
wind or solar farms.Data Centres also generate large quantities of waste heat which could be
utilised in district heating systems {xxiii}.
To meet the greenhouse gas emissions targets set out in the Paris Agreement,and in the
recently published Climate Action and Low Carbon Development Bill,it is paramount to examine
the impact that energy supply of data centres will have on net emissions.Furthermore,it is
crucial that every City and County Council takes into consideration the cumulative impact of
data centres’energy demand on a nationwide basis,as opposed to examining impact solely on
a case-by-case basis.
3.Public Participation and People-led Policy
Recommendations:
●Outside the development of this plan,the council should lead annual local climate
dialogues which serve to inform communities about the ongoing transition to a low
carbon society and seek their opinions,ideas and consent.
●The Climate Action and Environment office,or equivalent,within the council must be
adequately resourced,publicised and staffed.These offices should work closely with
local communities to improve education and access to information around environmental
issues,proactively engage in consultations and participatory processes which allow local
people to have a say in the energy transition in their area.
●Wherever practically possible,participatory processes should be designed in a
participatory way,with input from representatives of all groups who are expected to take
part.
●Special outreach efforts must be made to include disadvantaged or marginalised groups
in participatory processes.Those running participatory processes should keep a detailed
record of the participation of marginalised groups and of best practices that serve to
increase this participation.
●Support and establish community energy projects throughout the lifetime of the
Monaghan county development plan.
Throughout the lifetime of the Monaghan county development plan,Ireland’s transition to a low
carbon society is entering its most crucial decade.It's vital that it should be centred around
providing people and communities with clean,affordable and reliable energy.The best way to
do so is to ensure citizen participation at all levels and stages of the energy transition.
There are many different ways in which people can participate in governance,ranging from
informing to consultation to partnership to citizen control,whereby community members control
the process (Armstein,1969){xxiv}.While all of these methods of participation are useful and
valid at different stages of policymaking,different forms of participation should be incorporated
into major decisions (such as energy infrastructure projects)to create a thoroughly participative
process;for example,informing and consulting at the stage of technical impact assessments.
Ideally,there should be citizen participation in the design of the participatory process itself,for
example through focus groups or workshops which feed directly into sub-national and national
policymaking.
Community participation and ownership has proved important for public acceptance of the
energy transition in countries where the transition is more advanced than in Ireland.For
example,in Germany,70%of the tax paid by wind turbine operators goes directly to the
municipality where the turbines are based.In Denmark,taxes on energy go into funds to
subsidise local initiatives for environmental improvement and community generation.Denmark
also requires that local communities have a 20%share in onshore or near-shore wind turbines.
Ownership measures like this are shown to increase community acceptance of energy transition
infrastructure,and can take the form of individual shares in an energy project,community
ownership of part of the infrastructure,or joint ventures between communities and developers
{xxv}.There are many renewable energy projects that,with the support of the Council,can be
developed.Numerous renewable energy exemplar projects exist around Europe,such as the
Edinburgh Community Solar Co-operative,which empowers the public to be part of the
transition to a low carbon society {xxvi}.
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