1. LNG, fossil fuels and new fossil fuel infrastructure
Chapter 12 of the Draft Kerry County Development Plan 2022-2028 includes the following statement:
"KCDP 12-3
Facilitate the expansion of the gas network, including the facilitation of a gas importation facility in the Tarbert/Ballylongford Landbank, and the expansion of the network to the Kerry Hub and Knowledge Triangle settlements of Tralee, Killarney and Killorglin."
Assuming that this refers to plans for supporting the construction of a Liquefied Natural Gas (LNG) terminal at Tarbert, we urge Kerry County Council to amend their County Development Plan to oppose, rather than actively support the development of LNG infrastructure.
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}.
The construction of an LNG terminal off the coast of Kerry would also be in conflict with national policy, which opposes construction of LNG and the importation of fracked gas (https://www.gov.ie/en/publication/f3774-policy-statement-on-the-importation-of-fracked-gas/).
Along with over 30 other climate and volunteer groups and Green Party TD Neasa Hourigan, Not Here Not Anywhere recently launched a campaign to Keep Ireland LNG Free, which has already attracted support from across political parties and the public. Constructing LNG terminals off the coast of Kerry would lock the county and country into fossil gas use for decades, risk the safety and health of surrounding communities, and interfere with Kerry’s and Ireland’s ambitious goals towards investing in renewable energy and becoming carbon free. For more information on the campaign and its supporters, see https://www.lngfree.ie/.
We further make the following recommendations:
- The Kerry County Development Plan should ensure a rapid phasing out of all fossil fuels including gas.
- The Kerry County Development Plan should not allow the expansion of the gas grid.
- The Kerry 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.
References:
Anderson, K and Broderick, J. (2017). “Natural Gas and Climate Change”. Manchester:Tyndall Manchester. {i}
Hmiel, B., Petrenko, V.V., Dyonisius, M.N., Buizert, C., Smith, A.M., Place, P.F., Harth, C., Beaudette, R., Hua, Q., Yang, B. and Vimont, I., (2020). Preindustrial 14 CH 4 indicates greater anthropogenic fossil CH 4 emissions. Nature, 578(7795), pp.409-412. {ii}
Borunda, A. (2021). Natural gas is a much ‘dirtier’ energy source than we thought. Science. https://www.nationalgeographic.com/science/2020/02/super-potent-methane-in-atmosphere-oil-gas-drilling-ice-cores/ {iii}
Smith, C. J., Forster, P. M., Allen, M., Fuglestvedt, J., Millar, R. J., Rogelj, J., & Zickfeld, K. (2019). Current fossil fuel infrastructure does not yet commit us to 1.5 C warming. Nature communications, 10(1), 1-10. {iv}
U.S. Energy Information Administration. (2020). Frequently Asked Questions (FAQs) - U.S. Energy Information Administration (EIA). Independent Statistics & Analysis – U.S. Energy Information Administration (EIA). https://www.eia.gov/tools/faqs/faq.php?id=907&t=8 {v}
Food & Water Watch. (2019). The Fracking Endgame – Locked Into Plastics, Pollution and Climate Chaos. https://www.foodandwaterwatch.org/sites/default/files/rpt_1905_fracking-2019-web_2.pdf {vi}
Oireachtas. (2019). Joint Committee on Climate Action debate - Wednesday, 9 Oct 2019. Houses of the Oireachtas. https://www.oireachtas.ie/en/debates/debate/joint_committee_on_climate_action/2019-10-09/2/ {vii}
International Institute for Sustainable Development. (2017). Zombie Energy: Climate benefits of ending subsidies to fossil fuel production. https://www.iisd.org/sites/default/files/publications/zombie-energy-climate-benefits-ending-subsidies-fossil-fuel-production.pdf {viii}
Artelys. (2020). An updated analysis on gas supply security in the EU energy transition. https://www.artelys.com/wp-content/uploads/2020/01/Artelys-GasSecurityOfSupply-UpdatedAnalysis.pdf {ix}
ENTSO-G. (2017). Union-Wide Security of Supply Simulation Report. Brussels:ENTSO-G. Available: https://www.entsog.eu/sites/default/files/entsog-migration/publications/sos/ENTSOG%20Union%20wide%20SoS%20simulation%20report_INV0262-171121.pdf {x}
Ervia. (2018). A Look at Irish Gas Market. Dublin: Ervia. Available: https://www.gasnetworks.ie/corporate/company/our-network/irish-gas-market-overview/The-Irish-Gas-Market-Overview.pdf (Accessed 17 Oct 2020) {xi}
Evans, S. (2019). Analysis: Half of UK’s electricity to be renewable by 2025. Carbon Brief. Available: https://www.carbonbrief.org/analysis-half-uks-electricity-to-be-renewable-by-2025 {xii}
Gaventa, J., Dufour, M, Bergamaschi, L. (2016). More security, lower cost: A smarter approach to gas infrastructure in Europe. Available: https://www.e3g.org/publications/more-security-lower-cost-a-smarter-approach-to-gas-infrastructure-in-europe/ {xiii}
2. Data Centres
We welcome the following statement in Chapter 12:
“KCDP 12-5
Consider the sustainable development of Data Centres at appropriate locations powered by renewable energy where it can be demonstrated that there will be no significant adverse impact on the built and natural environment, visual character of the landscape or on residential amenities. Seek opportunities to recover waste heat to support potential decarbonisation projects such as district heating schemes.”
We further recommend that:
- 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. It may not be permitted for data centres to be powered through fossil fuels and simply “offset” their fossil energy use through Purchase Power Agreements (see below).
- Existing centres should be required to transition rapidly to onsite or new off site renewables.
- Wherever technically possible, heat generated from a data centre should be required to 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.
Eirgrid. (2020). All Ireland Generation Capacity Statement. Dublin: Eirgrid. Available: https://www.eirgridgroup.com/site-files/library/EirGrid/All-Island-Generation-Capacity-Statement-2020-2029.pdf (Accessed 2021, May 16) {xiv}
Irish Academy of Engineering. (2019). Electricity Sector Investment for Data Centres in Ireland. Available: http://iae.ie/wp-content/uploads/2019/08/Data-Centres-July-2019.pdf (Accessed 2019, September 22) {xv}
Lillington, K. (2018). Net Results: Data centres need to power down their energy requirements. Available: https://www.irishtimes.com/business/technology/net-results-data-centres-need-to-power-down-theirenergy-requirements-1.3561745 (Accessed 2019, September 22) {xvi}
Climate Home News. (2017). ‘Tsunami of data’ could consume one fifth of global electricity by 2025. Available: https://www.theguardian.com/environment/2017/dec/11/tsunami-of-data-could-consume-fifthglobal-electricity-by-2025 (Accessed 2019, September 22) {xvii}
Department of Business, Enterprise and Innovation. (2018). Government Statement on the Role of Data Centres in Ireland’s Enterprise Strategy. Available: https://enterprise.gov.ie/en/Publications/Publication-files/Government-Statement-Data-Centres-Enterprise-Strategy.pdf (Accessed 2019, September 22) {xviii}
Taylor, C. (2018). Data centre demand to lead to higher energy prices. Available: https://www.irishtimes.com/business/energy-and-resources/data-centre-demand-to-lead-to-higher-energyprices-1.3581998 (Accessed 2019, September 22) {xix}
Tech told pay for wind farms. (2020). Irish Examiner. https://www.irishexaminer.com/business/arid-30917493.html {xx}
Chernicoff, D. (2016). How data centers pay for renewable energy. Available: https://www.datacenterdynamics.com/analysis/how-data-centers-pay-for-renewable-energy (Accessed 2019, September 22) {xxi}
Sustainable Energy Authority of Ireland. (2019). Renewables. Available: https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&ved=2ahUKEwi69MPZiPTuAhUvThUIHXzMA9wQFjADegQIARAD&url=https%3A%2F%2Fwww.seai.ie%2Fpublications%2FRenewable-Energy-in-Ireland-2019.pdf&usg=AOvVaw0H1q38mxqi3ITr3FrjO8O8 (Accessed 2019, September 22) {xxii}
Ramboll Group. (2019). Unprecedented data centre surplus heat recovery to fuel district heat network. https://ramboll.com/projects/rdk/unprecedented-data-centre-surplus-heat-recovery {xxiii}