Minister Eamon Ryan

Minister for the Environment, Climate and Communications

Department of the Environment, Climate and Communications

29-31 Adelaide Rd


D02 X285

Dear Minister Ryan,

We are writing to request further information and express our concern regarding the recent announcement of plans for up to seven new fossil-gas-fired power plants in Ireland, and the associated policy statement on security of electricity supply. These plants will potentially generate an additional 2,000 MW of fossil gas power, at a time when rapid fossil gas phase out is required. Fossil gas demand must reduce consistently from 2020 onwards, by at least 11% by 2030 and 37% by 2040, if we are to achieve 2050 decarbonisation targets and avoid the worst effects of climate change. We have three key concerns.

The first relates to drivers of demand for new fossil gas power and we would like to request further information on what would be powered by this additional 2,000 MW of capacity. Like others, including Eirgrid and the CRU, we are concerned that data centres are driving new power demand (increasing both peak and average levels) and placing an inordinate burden on the grid. While we welcome the new CRU guidelines relating to grid connection for data centres, these exclusively address generation capacity/security of supply, and entirely neglect the complementary constraints of rapid decarbonisation. Currently seven fossil-gas-fired power plants are proposed as part of planning applications for four data centres in Co. Clare, and South Co. Dublin, illustrating that fossil gas is the first choice for on-site generation. We recommend urgent revision of government policy on data centres in light of their climate and energy security implications and a moratorium on their development pending a full policy review and public consultation.

The second concern relates to fossil fuel lock-in, and high risk that these deployments will undermine achievement of national carbon budget constraints already in the immediate future (budget periods 2021-2025 and 2026-2030). New fossil gas power plants typically have a useful life of 30-40 years. For the new plants to be commercially viable under budget-constrained pathways to rapid national decarbonisation, they must be futureproofed to enable early transition to zero carbon electricity generation. We would like to request further information on provisions that have been made to ensure such futureproofing at the design and procurement stage, and to explicitly exclude any state indemnity for future stranding of privately owned generation assets.

Finally, and perhaps most seriously, we are extremely concerned with the ongoing deterioration in overall Irish energy security. New fossil gas electricity generation at the proposed scale exacerbates national exposure to geopolitical disruption of fossil gas supply and is not compatible with long term energy security for Ireland. As you are aware, there are already identified technical alternatives to fossil fuels for firm electricity generating capacity. In particular, chemical electrofuels (e.g., hydrogen and ammonia) clearly offer technical routes toward very large scale (TWh+) energy storage which, in tandem with other measures (migration away from current liquid fossil fuels in transport and heat to the use of zero-carbon energy carriers, specifically electricity and hydrogen) could allow a significant majority of all Irish energy needs (not just current electricity consumption) to be met from indigenous very low-GHG sources. This would consist primarily of wind, onshore and offshore, but also with some significant solar PV, all coupled with very large scale electrofuel storage. This presents the possibility of a “triple-win” on energy security, sustainability and economic development, by allowing Ireland to achieve global leadership in the commercialisation and large-scale deployment of these technologies. Adopting this approach would align with the necessary discipline of progressively tightening national carbon budgets and would also make domestic policy consistent with Ireland’s recent international commitments at COP26 in relation to methane emissions reduction and oil and gas phase out.

We would welcome the opportunity to meet with you to discuss the above at your earliest convenience and would be happy to provide further clarification if necessary.

Le meas,


Phil Kearney                                Aideen O’Dochartaigh

Chair, An Taisce                           Not Here Not Anywhere

[email protected]                        [email protected]