EirGrid’s “new” Development Strategy – what it really means

EirGrid Development Strategy

In response to ever-increasing legal, political and economic pressure, the Department of Conservation, Energy and Natural Resources have released another glossy publication through their mouthpiece EirGrid.

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The document is largely technical mumbo-jumbo on which I am not qualified to speak, and I look forward to my colleagues doing that. I restricted myself to reading the introduction to this grand document and interpreting it into language we can all understand.

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The quotation is EirGrid speaking, the subsequent paragraph is my understanding.

 

“This draft strategy responds to feedback received from the public, as a key part of our renewed efforts to encourage greater participation in our decision-making process. It also reflects an updated view of the economic context, and incorporates our growing experience of promising new transmission technologies.”

The level of public opposition and ensuing political embarrassment has forced us, kicking and screaming, to adopt a different tack. Many commentators have pointed out that the level of expenditure we were intending will bankrupt this country, again, and EirGrid currently enjoys a similar credibility level as that enjoyed by Allied Irish Bank. In our desperation we have had another look at other technologies, most of which were suggested to us in 2008 but which we ignored, as our plans were set long before public consultation was even suggested. We will try and obscure the fact that these alternate technologies are no longer state-of-the-art and have been used in America for over a decade by making much of the fact that this will be the first time that they are used in Ireland, a bit like the oral contraceptive that was introduced into Ireland in 1985 (The Health (Family Planning) (Amendment) Act, 1985) despite being marketed to the world in 1960.

 

“The final strategy, to be published later this year, will support Ireland’s wider policy objectives; economic, environmental and social – including the Government’s Action Plan for Jobs and the IDA’s Regional Development Strategy.”

Oh shit, it’s the election next year, the economy is still in a mess and unemployment is really high, despite our manipulation of the jobs statistics. How do we justify spending billions into the pockets of our big business brethren when all they offer in return are a few short-term low-paid jobs digging foundations for wind turbines? We can’t, but let’s just kick for touch at the moment, there’s still over a year to go and maybe things will pick up or we can engineer another sex scandal with Sinn Fein.

 

“In addition, it will take into account the views of communities and representative groups, whilst also ensuring sufficient capacity is available for regional economic development.”

Ha, you culchie eejits, why would we ever listen to you? We will continue to pretend to listen but believe us when we say it’s full steam ahead with the wind farms and the monster pylons to service them.

 

“In managing the overall cost, we will do our part to ensure that Ireland remains competitive – fostering economic growth, attracting new investments, and supporting indigenous jobs.”

In our efforts to supplement our already scandalous pensions we will continue to destroy the food industry, the tourist industry, and the racehorse industry, not to mention destroying numerous scenic areas, historical monuments, and let’s not forget the health of our citizens and their children. All this to create electricity for export despite nobody wanting it at our incredibly expensive Irish prices.

 

“As we considered the options for our new strategy we faced a key question: How do we balance all these considerations? We have to ensure that our plans meet Ireland’s electricity needs, without placing too great a burden on communities, or too high a cost on industry. How much investment is needed to adequately future-proof the grid? Too little investment now may have negative economic impacts in the future.”

We need to be careful not to show our hand too early and create massive public opposition. Sure, those eejits at Irish Water are classic examples of that. No, we need to sell slurry as if it’s chocolate pudding, and appear reasonable and honest to boot. That’s a tall order, but sure, that’s why we have all these expensive PR firms charging us millions, and anyway, those poor fools don’t understand the levy figures on their ESB bill.

 

“We want to deliver best value for the Irish people. We will build new infrastructure only when this is the right solution. We will select appropriate technology to get more from existing grid infrastructure, depending on the needs and circumstances in each case.”

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We want to make ourselves tons of money in the short-term (before we are voted out) and are willing to walk on dead bodies to do it. We will build what we want, where we want it, anytime we bloody well feel like it – the planning laws are a joke.

 

“In summary: We will do more with the existing grid and make it work harder – before we build new transmission infrastructure.”

Those people in Waterford are a pain in the hole and we need to reconsider our strategy there – hopefully we can shut them up by flogging them old American technology which we can pick up for a song and install before they realise it emits even more cancer-causing radiation than the pylons. As far as the North-South interconnector is concerned, screw them – we have the planners in our pocket and it’s full steam ahead.

About Neil van Dokkum

Neil van Dokkum (B. SocSc; LLB; LLM; PGC Con.Lit) Neil is a law lecturer and has been so since arriving in Ireland from South Africa in 2002. Prior to that Neil worked in a leading firm of solicitors from 1987-1992, before being admitted as an Advocate of the Supreme Court of South Africa (a barrister) in 1992. He published three books in South Africa on employment law and unfair dismissal, as well as being published in numerous national and international peer-reviewed journals. Neil currently specialises in employment law, medical negligence law, family law and child protection law. He dabbles in EU law (procurement and energy). Neil retired from practice in 2002 to take up a full-time lecturing post. He has published three books since then, “Nursing Law for Irish Students (2005); “Evidence” (2007); and “Nursing Law for Students in Ireland” (2011). He is an accredited and practising mediator and is busy writing a book, with Dr Sinead Conneely, on Mediation in Ireland. His current interest is Ireland’s energy policy and its impact on the people and the environment. He is also researching the area of disability as a politico-economic construct. Neil is very happily married to Fiona, and they have two sons, Rory and Ian.
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4 Responses to EirGrid’s “new” Development Strategy – what it really means

  1. SAFE AMP says:

    Top class Neil…strategy is a great example of ‘paper not refusing ink’….thanks again.

    Margaret

  2. And we will be sure to publish the “Public Acceptance Trend” showing that there are now less objectors than last time if all you good folks don’t get your pens out and respond to the 7 questions in the online submission. These are:
    Q1. What are your views on our proposals to develop the electricity grid to support current plans for new investment and jobs?
    Q2. What are your views on our other reasons for continuing to develop the electricity grid?
    Q3. What are your views on: Strategy Statement 1 – Optimise the current network in order to minimise requirements for new infrastructure?
    Q4. What are your views on: Strategy Statement 2 – Consider all practical technology options for network development?
    Q5. What are your views on: Strategy Statement 3 – Foster open engagement and inclusive consultation with local communities and stakeholders as a central principle to developing the grid?
    Q6. What are your views on EirGrid’s proposal to meet project needs but with reduced power capacity in the long term?
    Q7. Do you have any other comments on this draft review of our Grid Development Strategy? If so, please provide these below.

  3. Pat Swords says:

    The 17th Century French Author Francois de La Rochefoucauld pointed out:

    – To establish oneself in the world, one has to do all one can to appear established.

    He also pointed out:

    – We confess our little faults to persuade people that we have no large ones.

    Me thinks he would have recognised some of this craft work in how Eirgrid are now trying to spin the situation in the above. However, one of the first rules of Public Relations is; “if the public think you have a problem, you have a problem”. So what is Eirgrid’s problem? This is important as their problem is becoming a lot of other peoples problem as well. So let’s go back to the origin of all of this and the so called ‘key’ decisions, which got us here.

    First of all National Development Plan 2007-2013, which is dated January 2007 and had as a subcomponent of its projected €184 billion investment:

    – “Investment in key strategic energy infrastructure projects including the East/West and North/South interconnectors and ongoing investment in sustainable energy with a view to meeting the target of 15% of electricity production from renewable sources by 2010”.

    – “The projected Energy Network Investment Programme 2006-2010 includes:
    • 350,000 new connections;
    • 50 new transmission/HV stations;
    • 1100 MW connections for renewables; and
    • 400 km transmission lines”.

    – “During the period 2007-2013, the main focus of investment by EirGrid will entail improvement of the transmission network for electricity to accommodate increased usage and enhance security of supply, to allow increased connection of sustainable and renewable energy sources to the network and to support greater interconnection with Northern Ireland and Great Britain. Expenditure of some €770 million is envisaged on the transmission system over the period of the Plan. Such work on the transmission system will be undertaken by ESB (as asset owner) and will be carried out in accordance with EirGrid’s Development Plan, as approved in advance by the CER. Ownership of the East-West Interconnector, for completion in 2012, will be vested in EirGrid”.

    Note, they never completed any of the legally binding Strategic Environmental Assessment for the above plan.

    Three months later in March 2007 we had “Delivering A Sustainable Energy Future For Ireland: The Energy Policy Framework 2007 – 2020”, which is the Government White Paper on Energy and often used in the first sentence of the ‘reasons and considerations’ on which An Bord Pleanala approves renewable infrastructure. As this clarified:

    – “The Government is committed to delivering a significant growth in renewable energy as a contribution to fuel diversity in power generation with a 2020 target of 33% of electricity consumption. Wind energy will provide the pivotal contribution to achieving this target. We also need a balanced portfolio of renewable technologies including biomass and ocean technology”.

    – “We will ensure through EirGrid’s Grid Development Strategy 2007-2025 and in light of the All-Island Grid Study the necessary action to ensure that electricity transmission and distribution networks can accommodate, in an optimally economic and technical way, our targets for renewable generation for the island to 2020 and beyond”. (Note the use of ‘island’, so two jurisdictions were now involved).

    – “We will ensure completion of the ongoing capital investment programme in transmission and distribution networks by 2010 and oversee further extensive investment in a programme expected to total €4.9bn up to 2013”.

    However, where did all of this come from? This was an issue which was perplexing me back in 2009 and led eventually to an appeal to the Commissioner for Environmental Information:

    http://www.ocei.gov.ie/en/Decisions/Decisions-of-the-Commissioner/Mr-Pat-Swords-Department-of-Communications,-Energy-and-Natural-Resources.html

    So what did I learn as to who wrote the basis, which established the above Energy White Paper and who ‘signed off’ on it?

    – “The Department said that Mr. Noel Dempsey T.D., then Minister for Communications Marine and Natural Resources, published the Energy Policy Green Paper, entitled “Towards a Sustainable Energy Future for Ireland”, on 1st October 2006″.

    – “The White Paper contained the Government’s agreed energy policy directions, and listed over 200 actions, targets and policies. The position of the Department is that documents such as the energy policy White Paper are statements of Government proposals and/or policy on particular policy issues. The energy policy White and Green Papers were considered, deliberated on and agreed by Government. The Department stated that various individuals worked on particular sections, but this does not affect the fact that they are Government statements, of proposals for energy policy”. (In other words the output of the Cabinet and their spin doctors).

    – “The Department does not describe the various schemes and polices in place on renewable energy as ‘the renewable energy programme.’ It says that renewable energy policy is part of overall energy policy which is set out in the Government’s 2007 White Paper on energy policy ‘Delivering a sustainable energy future for Ireland: The Energy Policy Framework 2007-2020.’ According to the Department, the then Taoiseach Bertie Ahern and then Minister for Energy Noel Dempsey wrote the forewords to the White Paper. The White Paper is a statement of overall collective Government policy and the paper was agreed by the Cabinet as a whole. The then Secretary General of the Department of Communications, Marine and Natural Resources would have had ultimate sign off of any draft documents in this context”. (So “we oblige by signing anything they require”!)

    There are a number of issues here; it’s known world wide that things were out of control in our little State as regards Governance in that period (not a whole lot better now). Secondly, there is an absolute denial, as above, that such a thing as a “renewable energy programme” actually exists in Ireland. The State’s position, repeated recently in the High Court, is for instance that the National Renewable Energy Action Plan (NREAP) is not a plan or programme, but as it states in its introduction, a “Summary of national renewable energy policy”. Furthermore, it is the “Government’s strategic approach and concrete measures” to comply with the renewable energy Directive 2009/28/EC. (Amazing, the measures are concrete, but they don’t constitute a plan!). Even more bizarre if one actually starts to download and read the planning decisions (Directions) issued by An Bord Pleanala for renewable energy projects, the first sentence (a) justifying them is a ‘hoot’, such as:

    – (a) the national policy with regard to the development of sustainable energy resources,
    – (a) the national policy with regard to the development of alternative and indigenous energy sources and the minimisation of emissions of greenhouses gases,
    – (a) the National Policy on the development of renewable energy including the National Renewable Energy Action Plan to deliver 40% of electricity from renewable resources by 2020,
    – (a) the national targets for a contribution of 40% from renewable energy by 2020; (this one is a real ‘hoot’ as our target for renewable energy under the Directive is actually 16%, not 40%, for which our ‘masters’ actually decided would be aided by a 40% target for renewables in the electricity sector).

    All sorts of wording appears, sometimes actually referring to nothing that actually exists in the real world as a ‘specific document’, but in all cases, the wording ‘renewable energy plan or programme’ is never ever used – ‘it’s a policy stupid’! Yet the dogs in the street know that a renewable energy programme is underway involving countless projects related to turbines and pylons. However, from a legal perspective, this renewable programme does not and cannot be allowed exist. Why? Well the billions of Euros and countless planning approvals that are being shoveled into this renewable madness derive from the cabinet ‘spin doctors’ of 2006 to 2008, no other form of approval exists. Are they entitled to do this? Of course not. The legal framework has numerous ‘checks and balances’ related principally to Regulatory Impact Assessment, Strategic Environmental Assessment and their associated public participation, i.e. following adoption of a policy, all the detailed analysis and subsequent public participation has then to be done before you can adopt it as a plan / programme and actually start implementing it.

    Unfortunately, ‘checks and balances’ as we well know were not in vogue in the mid-2000s and the bigger one dreamed, the bigger the ‘wad’ of money, which could be justified and drawn down upon. So this is Eirgrid’s problem, they completely lost the run of themselves in the mid 2000s and ‘justified’ to the complete idiots we had then entrusted for our decision making, some completely crazy projects. These idiots hadn’t a clue and as the ‘checks and balances’ were by-passed, we ended up with the unbelievable situation that these billions of Euros were essentially committed, without any proper questions being asked, let alone analysis being done. So once the money starts to flow, the gravy train takes over and nobody wants to ask why or what alternatives, as it would spoil the ‘party’. Furthermore, why even consider these pesky questions, when your pals in An Bord Pleanala can ‘troop out’ some descriptor (a) above to justify the necessary planning permission. In other words, as the 17th Century French wit would have pointed out, you just have to be seen to be established.

    It took an awful lot of effort, which is now part of Communication ACCC/C/2013/96, to obtain the partly redacted questionnaires on the Irish Projects of Common Interest below:

    http://www.unece.org/fileadmin/DAM/env/pp/compliance/C2013-96/Communication/Attachment_6_Questionnaires.pdf

    There is an Eirgird aspect in the above questionnaires, both in relation to Grid Link and the North South Interconnector. If we take Grid Link first, then on examination:

    – “This investment is planned primarily to facilitate the integration of 1,283 MW of wind generation in the south of the country”.

    – “Connection offers have been made to 1,280 MW of renewable generation in the south”.

    – “The connection of such capacity can only be facilitated if further interconnection is installed to provide access for this generation to the British and continental European markets, in addition it win facilitate future interconnection to Great Britain or France”.

    If we look at the North South Interconnector:

    – “The additional grid transfer capacity provided by this North South 400 kV interconnection project is essential to
    allow access to a larger market for the new renewable generation, particularly for Northern Ireland wind generation in times of high wind conditions and low local demand. This project therefore indirectly allows the connection of 600 MW in Northern Ireland, i.e. the equivalent of the additional grid transfer capacity initially provided by the link”.

    So let’s get real here, neither Grid Link nor the North South Interconnector are stand alone projects. Neither are they simply a ‘policy’. They are part of an overall very specific plan or programme, which is being funded and implemented, but as a legal entity doesn’t exist. Guess why? One could also point out that Ireland, the United Kingdom and the European Union have all ratified UNECE’s Espoo Convention on Environmental Impact Assessment in a Transboundary Context, which is of course engaged by the two little Eirgird projects above and is also part of Community Legislation following its ratification by the EU in 1997.

    So in reality, these Eirgrid projects are part of a greater transboundary ‘gig’, which is not just a one-off project in scope, but a series of multiple projects involving huge numbers of turbines and a number of interconnectors (more details in the Questionnaires in the UNECE link on ACCC/C/2013/96 above). So is this a transboundary ‘plan or programme’? Dead right it is. One then has to address the UNECE’s Kyiv Protocol on Strategic Environmental Assessment, which was a Protocol to the Espoo Convention above. As it was ratified by the EU in 2003 it is also therefore part of Community law. Furthermore, it is engaged under the circumstances below, which in simple terms means plans and programmes involving high voltage lines and wind turbines.

    – 2. A strategic environmental assessment shall be carried out for plans and programmes which are prepared for agriculture, forestry, fisheries, energy, industry including mining, transport, regional development, waste management, water management, telecommunications, tourism, town and country planning or land use, and which set the framework for future development consent for projects listed in annex I and any other project listed in annex II that requires an environmental impact assessment under national legislation.

    It is worth while spending some time actually reading the Espoo Convention and the Kyiv Protocol at the link below:

    http://www.unece.org/env/eia/welcome.html

    This transboundary legislation is more specific than what the EU has actually codified into its current Directives on Environmental Impact Assessment and Strategic Environmental Assessment, although once transboundary issues are engaged, so too are the legally binding Treaties with UNECE. Points to note in the Espoo Convention are the requirements for Environmental Impact Assessment Documentation and consultations related to: “Possible alternatives to the proposed activity, including the no-action alternative”.

    In the Kyiv Protocol repeated emphasis is placed on ‘human health effects’, which are given equal weight to environmental effects. Indeed, there is a specific requirement for formal consultation with environmental and health authorities within the overall Strategic Environmental Assessment process.

    So where does this leave us? Were Eirgrids ambitions of the 2000s extremely premature and ill advised? The answers from a technical, legal, environmental and financial perspective, not to mention an ethical perspective, are most definitely yes. There were a huge numbers of steps with associated checks and balances, not only within this jurisdiction, but other jurisdictions, which had first to be completed, before viable project(s) could emerge. None of this has been done and there is no sign of it being done.

    Arthur W. Page in 1927 became the first person to hold the title of vice president of public relations for AT&T. He is famous for his remark:

    – “All business begins with the public permission and exists by public approval.”

    Eirgird are certainly ‘spinning’ that they have legitimate projects, when in reality if one digs beneath the spin, the reality couldn’t be different. They need to be reminded of this. The fact that Catherine McGuinness, the former Supreme Court Justice and chair of the Government-appointed Independent Expert Panel, hasn’t pulled the plug on this already, is simply another indication of the lack of independence and integrity of our public service. One can only conclude from the above, that in Ireland the Government and their spin doctors decide everything and the law is for academics, i.e. a banana Republic

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