Start Preparing Your Submissions

Ref: MS-2017 11 – please quote this reference on all correspondence 
Dear Deputy,
I refer to your email received 21 April 2017 in relation to the new RESS scheme and financial support.
My Department is currently developing a proposed new Renewable Electricity Support Scheme (RESS) which will be designed to assist Ireland in meeting its renewable energy contributions out to 2030.
The new scheme design requires detailed economic analysis on the viability and cost effectiveness of supporting several renewable technologies at various scales, including onshore and offshore wind, Solar PV (both ground mounted and rooftop), Bio-Energy, Ocean (Wave and Tidal) etc. Once this analysis is complete, my Department will publish a public consultation on the design of the new support scheme. There will be many decisions to be made on this support scheme with regard to scale, technologies, cost, eligibility and – in particular – how communities will have a greater involvement than in previous schemes. 
Following the outcome of this public consultation, and before any new scheme is introduced, it will need to secure Government approval and state aid clearance from the European Commission. Subject to this, it is expected that the new scheme will become operational in the first half of 2018.
Details of the next public consultation will be advertised on my Department’s website and we would welcome your response to this consultation.
I trust this information is of some assistance.

Yours sincerely,
Denis Naughten, T.D.
Minister for Communications, Climate Action & Environment
For a consultation of this importance and magnitude, I would expect the Minister to post full page notices in the national dailies, radio and TV, and a consultation period of at least six months. The usual notice hidden in the layers of the departmental website with two weeks to go does not cut the mustard.

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 full-time practice in 2002 to take up a 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). His current interest is 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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3 Responses to Start Preparing Your Submissions

  1. Pat Swords says:

    The UNECE Compliance Committee published at the end of February its: “Second progress review of the implementation of decision V/9g on compliance by the European Union with its obligations under the Convention”, this being related to the non-compliance of the NREAPs with the Aarhus Convention:

    Click to access Second_progress_review_on_V.9g_EU_final.pdf

    Point 27 of this kind of sums it all up:

    27. The communicant queried why the Commission, in its Consultation Questionnaire for the “Preparation of a new renewable energy directive for the period after 2020” published on 19 November 2015, was only at the end of 2015 asking the public to “identify and ideally also quantify the direct and indirect costs and benefits such as macroeconomic effects, competitiveness effects, innovation, cost and cost reductions, environmental and health effects of the [Renewable Energy Directive]”. The communicant submitted that the European Union and member States should have had this information assessed and available to justify the decision-making that lead to the adoption of the Renewable Energy Directive in April 2009 and the NREAPs in June 2010. In contrast, the NREAP’s template’s section 5.3 “Assessment of the impacts” was expressly stated to be an optional table in which to set out the estimated costs and benefits of the renewable energy policy support measures. In keeping with its optional nature, nineteen member States left the table blank while others inserted little or no information. The communicant submitted that the Party concerned’s proposed plan of action in paragraph 15(b) above was thus completely unnecessary, because the information relating to the inadequacy of public participation was already available to them.

    Should have known these costs, benefits, impacts and alternatives before any money was ever given out in the first place. Simple logic and also the law.

  2. Neil van Dokkum says:


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