BENE’s submission to the Citizen’s Assembly

We made a submission on 11 August 2017 to the Citizen’s Assembly who were asking for input on “How the State can make Ireland a leader in tackling climate change”. Our submission is reproduced below. Comments are welcome, as always.

A transformative action to make Ireland a leader in tackling climate change

A difficult task:

The Chairperson of the Assembly, Mary Laffoy, acknowledged the difficult task facing Ireland in attempting to lead in tackling climate change when she said “The Assembly has been tasked with considering some of the most complex topics facing Irish society and on this occasion, I think it is fair to say we will be looking at something that has posed a challenge for societies right across the world”.

We are failing:

Evidence that we are currently failing the challenge comes from the most recent report of the Climate Change Advisory Council when it states [1] that “Ireland is unlikely to meet its 2020 targets for reducing greenhouse gas emissions by a substantial margin. This will have implications not only for 2020, but also for compliance with 2030 targets”.

SEAI estimates [2] that the costs of failure may be in the range of €120 to €150 million per % point, while EU data shows [3] that Ireland is one of the worst performers in this regard and we could miss our target by up to 3%. The 2020 penalty could be in excess of €300 million in that case.

Despite plenty of effort (and achievement):

This is despite Ireland already being the world leader in incorporating intermittent renewable electricity into our grid [4]. There are many areas in which Ireland is making good progress – these are referred to in multiple submissions to the Assembly, involving solar, wave, wind, biofuels, cycling, food production, energy efficiency, recycling, electric cars and so on.

What is needed?

Because we are still likely to fail to meet our targets despite all this good work, the Climate Change Advisory Council concludes [1] “It is urgent that effective additional policies are implemented to place the economy on an environmentally sustainable pathway to a low-carbon Ireland in 2050.

While the draft National Mitigation Plan identified a range of policy options, the introduction of, and commitment to new, cost-effective emission reduction polices and measures is essential”.

The 2017 National Mitigation Plan [5], an encouraging inter-departmental document, accepts that it is only the starting point in a task that will require “fundamental societal transformation

Our current situation:

So, Ireland is trying really hard to achieve something really challenging is failing quite significantly in the absence of policies and measures that will result in fundamental change.

Most commentators to date have referred to policies that result in incremental change, at best.

A transformative technology:

There is a technology we could deploy that is new to Ireland but has been proven internationally to be cost-effective at emissions reduction. It is a technology that many here have steadfastly ignored in recent decades and we are, therefore, not familiar with new developments that are expected to result in safer, cleaner and cheaper electricity that could be ideal for Ireland by 2028.

The technology, of course, is nuclear energy, which we have not needed to date because fossil fuels have been so cheap and we expected better results from our renewable energy efforts. This situation is rapidly changing, however. We are also becoming ever more aware of the social and technical challenges involved in deploying new wind and solar farms throughout the countryside.

So, as Ireland plans how to tackle climate change using evidence-based policies, it would appear to be negligent to proceed without at least evaluating the medium and long-term outlook for nuclear energy.

Progress with nuclear energy:

Just as other technologies become progressively safer, better and more affordable over time, so has nuclear energy developed in the period since Ireland rejected plans to build a nuclear power plant in Co Wexford in 1980. The coming decade will see the nuclear industry’s response to the accident at Fukushima, Japan, and the result is likely to be a nuclear unit that is simpler, safer, smaller and cheaper than any other technology.

These new nuclear plants are being designed so that they:

  • Are physically incapable of exploding (and cannot behave like a nuclear bomb!)
  • Are physically incapable of melting down
  • Produce much less waste than existing reactors
  • Produce waste that is much easier to store
  • Are an ideal size for Ireland
  • Are much cheaper than any other low emissions technology
  • Provide in-built energy storage to facilitate intermittent renewables.
Preparation for transformation:

It is proposed that Ireland should prepare the way to take advantage of nuclear energy if we choose to do so, perhaps as a replacement after 2025 for the coal-fired station at Moneypoint, Co Clare. If we find that we don’t need nuclear because it hasn’t developed as expected or because we somehow managed to meet or exceed our targets by other means, then so be it.

But, if we decide in 2025 that new nuclear is something that is in our interests to pursue, then it would be very useful to have used the intervening period to develop the planning, legislative and regulatory frameworks required for its deployment.

This time should also be used to educate ourselves about the evidence-based characteristics of nuclear energy, to help us understand why many developed societies (including Britain, France, Sweden, Finland, USA and others) have chosen nuclear energy to reduce emissions in a safe and cost-effective manner, and why many others are following suit – despite the negative publicity that often accompanies nuclear energy.

Although Nuclear already supplies almost half of the EU’s low carbon electricity, we should also be aware of its limitations, as no single energy source can cure all our energy problems in the most effective manner.

Specific proposals:

Specific actions that the Citizens Assembly should consider include:

  • Recommend that the group proposed in the National Mitigation Plan to consider the low carbon replacement options for Moneypoint include nuclear energy in their considerations
  • Recommend removal of the statutory prohibition on the construction and operation of nuclear power plants in Ireland. This would entail two simple amendments to current legislation [6] and would have no meaningful impact on an actual decision to construct a nuclear power plant in Ireland. It would, however, enable a genuine consideration of the pros and cons of nuclear energy in an Irish context
  • Recommend that all school textbooks be reviewed to ensure they contain accurate information on nuclear energy (and all low carbon technologies), as there is a tendency for them to concentrate almost exclusively on renewable energy.
How likely is nuclear energy in Ireland?

The International Energy Agency (IEA) and the Intergovernmental Panel on Climate Change (IPCC) each acknowledge that the climate change challenge will be much more difficult without nuclear energy. As such, nuclear energy is expected to form a significant part of the global effort in this regard. Nations with access to significant quantities of hydro and geothermal energy will not be as reliant on nuclear energy as other nations.

Because Ireland has limited access to hydro and geothermal, we are quite likely to require nuclear energy at some point in the future – unless another new technology becomes available, as concluded by the Climate Change Advisory Council.

Given the difficulty of the challenge facing us, as Mary Laffoy acknowledges, we cannot afford to be complacent about a policy action as relatively significant as nuclear energy, especially as the proposed actions can be implemented at very reasonable cost.

Implications of including nuclear in our Energy Policy? We can:
  • Continue our policy of decarbonizing electricity while electrifying loads
  • Gain a much higher degree of confidence that the policy will be effective
  • Continue to deploy electric vehicles and the less contentious of the wind and solar projects
  • Avoid environmental difficulties of replacing Moneypoint with biomass or carbon capture and storage (CCS)
  • Lower the cost of energy, benefitting society as well as the economy
  • Enjoy cleaner air, yielding better health outcomes
  • Continue with plans to decarbonize transport
  • Continue with plans to decarbonize agriculture
  • Continue to effect fundamental behavioural change in our citizenry
  • Demonstrate clear intent at taking meaningful action
  • Lead by example in the type of fundamental transformation that is required to achieve our aim
  • Demonstrate real leadership at EU level by arguing that, while CO2 reduction is imperative and energy efficiency is desirable, our renewable energy targets are merely political and serve no climate purpose if the CO2 reduction can be achieved without them. After all, the climate is indifferent as to how the CO2 is reduced, so why dilute our focus by chasing inconsequential targets?
Oral presentation:

A short presentation can be made to the Assembly on any aspect of this submission. A suggested presentation would simply and clearly outline why Ireland should consider these new nuclear units and the precautionary steps we should take now to prepare the way in case a consensus to deploy nuclear exists here in the medium term.

[1] Executive Summary of Climate Change Advisory Council Periodic Review Report 2017

[2] Alex White, TD, as Minister for Energy answering Dáil question 357, 28 January 2016.

[3] Eurostat Renewable Energy in the EU, 2017 report

[4] EirGrid is a world leader in the management wind-generated electricity – press release

[5] Foreword to the 2017 National Mitigation Plan by an Taoiseach, Leo Varadkar, TD.

[6] Electricity Regulation Act 1999 Section 18 (6) and Strategic Infrastructure Act 2006 Section 3 (37K)

Author: Denis Duff

Denis Duff is a Chartered Engineer with a lifetime's experience in most aspects of electricity production - power station design, construction, commissioning, operation, maintenance and decommissioning - with experience also of power purchase contracts and management development. He has worked with Wind, Hydro, Oil, Gas and Peat in Ireland, Asia and Africa.

5 thoughts on “BENE’s submission to the Citizen’s Assembly”

  1. Excellent submission . A change of heart and mind with respect to nuclear would be the ” fundamental societal transformation ” that Ireland needs to go from laggard to leader . We know that it can work and has worked as a significant element of the decarbonization strategy elsewhere . Decarbonize electricity and electrify everything !

    1. Agreed, Pat.

      The Citizens Assembly have been brave before, including when they considered the 8th amendment – I expect they will be as brave this time, too, as there is little hope for success in becoming leaders of anything without being brave!

  2. Unfortunately the Citizens’ Assembly final report (received April 18th 2018) has no mention of the word ‘nuclear’ which I find quite shocking after all the guff about hearing all voices.

    1. The steering group chose to present on only the most popular of the suggestions made in the submissions with little regard for whether they could actually make Ireland a leader in tackling climate change, which was their remit. Even then, they were meant to present both sides of the argument on any topic they did present, but failed to do so.

      To say the process was flawed is an understatement. That each of the proposals was passed by an overwhelming majority shows how poor an argument was made in the presentation of each of them, as the down-side was not presented at all. Shocking!

      Most shockingly, they didn’t adhere to their statutory terms of reference and showed no remorse when I tackled them on this point in extensive correspondence between weekend 1 and weekend 2.

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