Submission to the Public Consultation on the Design and Implementation of a Renewable Heat Incentive The Renewable Heat Incentive (RHI) subsidy aims to make savings against penalties likely to be incurred by Ireland for not meeting the EU 20% Renewables by 2020 obligation. However, the Consultation Document fails to show that it will in fact save public money. An RHI would commit the State to long-term funding of a biofuel heat sector despite there likely only being a couple of years to make savings against compliance costs. There are financial, administrative, air pollution and climate reasons to avoid expansion of domestic biofuel production and combustion. This Document fails to make a substantive, quantified or costed case to address these problems. Due diligence in the Department of Finance, DPER and in public consultation requires a far more finalised proposal to be made available for comment once more costing and academic assessment is done. An Taisce favour charging a carbon pollution fee on all carbon dioxide emissions, including those from burning biomass at the same rate as the current carbon tax on fossil fuels. This revenue raised can then be used to fund the retrofit measures in both the ETS and Non-ETS sectors that will reduce both heat demand and emissions. If they meet strict sustainability criteria, showing real emission reductions, biomass and biogas production could be funded on a feed-in tariff basis like other renewables such as solar where a subsidy makes sense. Download the submission here.