About Chambers Ireland

Chambers Ireland is an all-island business organisation with a unique geographical reach. Our members are affiliated Chambers of Commerce in the cities and towns throughout the country – active in every constituency. Each of our member Chambers is central to their local business community and all seek to promote thriving local economies that can support sustainable cities and communities.

Our Network has pledged to advocate for and support the advancement of the United Nations Sustainable Development Goals (SDGs). As SDG Champions, we use the Goals as a framework to identify policy priorities and communicate our recommendations. We have a particular focus on five of the goals encompassing decent work and economic growth (SDG 8), sustainable cities and communities (SDG 11), Gender Equality (SDG 5), Industry, Innovation, and Infrastructure (SDG 9) and climate action (SDG 13). 1

Our Perspective

Climate Action Targets

A long-term focus on reaching our climate targets requires coordinated action and a clear roadmap for all stakeholders across both the public and private sectors. Successive Climate Action Plans have been instrumental in defining that roadmap and plotting our course to climate neutrality, however, previous iterations of the Plan have failed to result in adequate levels of progress. Minister for the Environment Darragh O'Brien will seek Cabinet approval on Tuesday 15 April for this year’s Climate Action Plan (CAP).

We have been set the goal to reduce the extent of further global warming, by pursuing and achieving, “by no later than the end of the year 2050, the transition to a climate resilient, biodiversity-rich, environmentally sustainable and climate neutral economy”. The interim goal of achieving a 51% reduction in greenhouse gas emissions by 2030 compared to 2018 levels also sets a clear parameter for the actions we need to take and the level of activity that needs to be implemented if we are to meet these targets and achieve meaningful results.

The State lags well behind its EU peers in terms of reducing CO2 emissions and this is largely down to inconsistent action in advancing our infrastructure. Decades of underinvestment, issues with planning and regulatory uncertainty have resulted in hindering projects which are vital to meeting our climate targets. This not only impacts our competitiveness, but critically means that meeting those targets is increasingly out of our reach.

The statistics are bleak; in 2022, Ireland had the second highest emissions of greenhouse gases per capita in the EU27 at 11.7 tonnes of carbon dioxide equivalent per capita. Ireland's emissions were 56% higher than the EU27 average of 7.5 tonnes. 2 Last year the Environmental Protection Agency noted how Ireland will achieve a reduction of only 29% in greenhouse gas emissions by 2030, compared with the target of 51%. 3 It also noted the following essential statistics:

To achieve a reduction of 29% would require full implementation of a wide range of policies and plans across all sectors and for these to deliver the anticipated carbon savings. Almost all sectors are on a trajectory to exceed their national sectoral emissions ceilings for 2025 and 2030, including Agriculture, Electricity and Transport. The first two carbon budgets (2021-2030) will not be met, and by a significant margin of between 17 and 27%. Ireland will not meet its EU Effort Sharing Regulation target of 42% reduction by 2030.

The statistics show that the State must rapidly accelerate renewable infrastructure projects, enabling sectors to decarbonise and enabling renewable energy generation will be key towards meeting our targets.

Diversifying our energy mix

In essence, energy diversification is not just a technical challenge — it’s a national priority. It weaves together climate action, economic opportunity, energy independence and social wellbeing. For Ireland, embracing a broader energy mix means shaping a future that is not only greener but also fairer and more secure.

Diversifying our energy mix is a critical step for the State as it looks to secure a stable and economically resilient future. For too long Ireland has relied heavily on imported fossil fuels to meet its energy needs. This overreliance exposes the country to external shocks, including geopolitical tensions, supply chain disruptions, security risks and their associated price distortions. By broadening the range of energy sources — especially through investment in renewables like wind, solar and bioenergy — Ireland can reduce its vulnerability and take greater control over its own energy destiny.

Beyond energy security, there is a pressing environmental imperative. We are subject to legally binding emissions reduction targets under both EU law and our own Climate Action Plan. 4 Meeting these goals will require a decisive shift away from fossil fuels and toward cleaner sources of energy. Biomethane and Green Hydrogen will both play a critical role in doing that. A more diverse energy mix, with renewables at its core, is essential to decarbonise not just electricity, but also harder-to-reach sectors like transport, heating and industry. By spreading our energy supply across multiple sources, including emerging technologies like Green Hydrogen we create a more flexible system capable conducive towards meeting those targets.

There are also strong economic incentives for diversifying. Renewable energy can become a cornerstone of regional development, particularly in coastal and rural areas where wind, biomass, and solar resources are strongest. This is a point which the Chamber Network resonates strongly with given the geographical reach of our all-island organisation. Offshore wind, for instance, offers enormous potential to create high-quality jobs, drive investment in ports and infrastructure, and establish Ireland as a clean energy exporter. At the same time, a more varied mix protects both businesses and consumers from the kind of price volatility seen in global markets and offers more predictable costs in the long term.

Essential Investment

We strongly support substantial investment in infrastructure development for renewables. Large-scale investment is required to develop Biomethane, Hydrogen and other alternative energy sources.

The National Development Plan (NDP) has ambitious decarbonisation targets, aiming to significantly reduce carbon emissions by 2030, and sustained investment will be crucial to meet those targets within the short timeframe. Biomethane is a crucial component of the NDP and is expected to account for 10% of gas demand. Support schemes will be fundamental for stimulating growth in the biomethane sector particularly as they will aid in creating market certainty for developers. To that end, the availability of grants and financial incentives will be crucial.

The government has allocated €40 million in capital grants for biomethane development, which is positive, there will need to be greater levels of support in subsequent phases to ensure the sustainability of biomethane production and to harness the latest research and innovation. These supports help reduce initial costs, encourage investment, reduce risk and bring down production costs. In addition, moving to larger-scale biomethane production improves efficiencies and reduces costs. Ultimately, clear signals from the government that biomethane will be supported, similar to the support provided to the wind energy sector, are required.

In terms of Hydrogen, Chambers Ireland have consistently advocated for further development and this is increasingly important as we look towards improving our energy security and striving towards independence from imported sources. The national Hydrogen Strategy5 and the EU Hydrogen Strategy6 both outline pathways for Hydrogen to become an intrinsic part of an integrated energy system. However, this will require significant investments in renewable hydrogen electrolysers and production. Adequate, sustained investment will be critical to developing the necessary associated infrastructure - including pipelines, storage facilities and terminals - to support large-scale deployment. Certainty will be essential for ensuring these significant capital projects can be built in respect to future demand.

Planning

Planning issues have frequently impacted key deliverables in the National Development Plan (NDP). Many projects critical to meeting our climate targets have been beset with delays and cost overruns that threaten their viability, create unnecessary disruption, exacerbate issues with the capacity of current systems and impact individuals, families, businesses and the economy more broadly.

The biggest issue with the planning system is the lack of organisational capacity. Decisions on licensing, grid access and planning permission take too long to be made and, without an effective, efficient and timely decision-making capacity in place, this has resulted in huge backlogs, delays and, crucially, very high costs. Waiting times are untenable and are having a detrimental impact on numerous crucial infrastructure projects, particularly in terms of increasing the costs required for investment as time progresses during judicial reviews and appeals, and the risk of losses if not approved.

While we welcomed the passing of the Planning and Development Bill last year7, alongside legislative reform we have advocated for stronger support and resources for planning authorities nationwide. Legislative reform is not the only ingredient required for improving the planning landscape; Local Government and the Courts and judicial system all need greater investment and resourcing. In addition, progress on integrating climate resilience into planning has also been slow, with many local authorities still struggling to fully incorporate climate adaptation measures. Inconsistent climate risk assessments and a lack of clear guidelines have hindered the integration of climate resilience into development plans. Without adequate integration, the State remains far from meeting its climate goals, undermining long-term sustainability, and leaving communities vulnerable to climate risks.

In the context of biomethane, we were pleased that the National Biomethane Strategy was published last year. Regarding planning, it is important to recognise the potential opportunities of utilizing farm and food waste to produce carbon-neutral biomethane gas with a national target of 5.7TWh by 2030, the planning system will have to support the delivery of anaerobic digestion facilities to meet this demand.

Questions

Section 10 of the report describes GNI’s gas network planning. It briefly references capacity upgrades to compressor stations in Scotland and the Southern Area Reinforcement (SAR) project, but does not include details on other network upgrades, future investments or timeframes for such projects. What additional information would you like to see presented in relation to infrastructure development?

Chambers Ireland supports substantial investment in infrastructure development. While the investment in upgrading capacity in compressor stations in Scotland is welcome – there must be additional large scale investment in infrastructure to develop biomethane and other alternative sources.

There is no form of renewable energy capacity that will not be useful when it comes to decarbonization and our approach will need to be flexible to ensure that, as we encounter the novel problems that will emerge over the next fifteen years, we will have access to all the tools that can address those challenges best. Biomethane and Hydrogen will both play a critical role towards that goal.

Biomethane has a role to play in reducing our carbon emissions significantly by 2030 and is expected to account for 10% of gas demand. Infrastructure supports will be essential to meet these targets within the short timeframe. They will help create a competitive advantage by justifying other infrastructure investments in certain areas and this will not only support the biomethane sector but also contribute to broader economic and environmental goals. Additionally, they will create market certainty for developers, which is often an impediment to many renewable energy projects being implemented.

Clear signals are required from government that biomethane will be supported. While the government has allocated €40 million in capital grants for biomethane development, higher levels of support will be required in subsequent phases. To stimulate investment in biomethane production, capital grants and financial incentives will be crucial. Such supports will help reduce the initial costs of setting up plants and related infrastructure. They additionally encourage investment, reduce risk, and help bring down production costs while also contributing to research and innovation.

Chambers Ireland would like to see Hydrogen being further developed and the objective set down in the national Hydrogen Strategy being realised. Hydrogen is a critical component in the EU's strategy to decarbonise its energy system and enhance our energy security. Increasing its production will help Europe – and Ireland - reduce its reliance on gas imports and enhance our energy security. In our opinion, the goal for Hydrogen production in Ireland should be a net reduction in CO2 equivalent emissions, and individual use cases should be considered according to that aim.

We have enormous opportunities to benefit from the exploitation of our renewable offshore energy resources, but we need far greater ambition to expand capacity and a Green Hydrogen industry that operates at scale is critical to store this energy over periods of weeks and months.

The EU Hydrogen Strategy outlines a pathway for hydrogen to become an intrinsic part of an integrated energy system, with significant investments in renewable hydrogen electrolysers and production. The development of hydrogen infrastructure, including pipelines, storage facilities, and terminals, are all essential to support large-scale deployment.

There are also the economic benefits for the State in terms of prioritising a Hydrogen network. At the European level plans are afoot for an expansive hydrogen network, including projects to expand or convert liquified natural gas (LNG) terminals to import hydrogen derivatives, and developing hydrogen gas pipelines and power capacity. Within this lies the potential for Ireland to develop into a net exporter of renewable energy by using excess wind-derived electricity to support hydrogen production. However, one of the primary constraints on the industry is the poor delivery of renewable energy on to the national electricity network. Ambition for renewables of all types needs to be increased at the highest level and the capacity of the transmission network needs to be improved so that it is commensurate with our national potential.

Do you agree with the assumptions GNI have used in their modelling (for example, treatment of biomethane, hydrogen and interconnection), and the presentation of supply and demand data?

Some targets included in the Ten-Year National Development Plan (TYNDP) are seen as very ambitious and challenging to meet. Enabling GNI to meet those targets should be front and centre of any target-setting.

GNI has modeled three different scenarios in the TYNDP: Low Demand, High Demand, and a middle scenario. Each scenario includes different assumptions about the pace of electrification and decarbonisation. The Low Demand scenario assumes high levels of gas disconnections, while the High Demand scenario assumes slower progress in electrification and decarbonisation.

Current trade uncertainty and unpredictability will have impacts on the supply and demand for natural gas. The imposition of tariffs and trade barriers can strain economic growth in Europe which affects the overall demand for natural gas. Higher costs and reduced market access can lead to a contraction in aggregate demand and output. Additionally, trade uncertainty can impact energy security by making it more challenging for Europe to secure stable and affordable natural gas supplies. This can lead to increased reliance on alternative energy sources and diversification of supply chains.

Table 6-2 presents the annual large new industrial and commercial demand forecasts. Should there be further consideration given to the detail and presentation of industrial and commercial and large energy user demand in this report? How could recent developments in this sector (such as CRU’s Review of Large Energy Users Connection Policy 25) be accounted for in the TYNDP process?

To account for the Commission for Regulation of Utilities (CRU)’s Review of Large Energy Users Connection Policy in the Ten-Year Network Development Plan (TYNDP) we should ensure that the TYNDP aligns with the objectives and recommendations outlined in the document. This includes addressing the needs and requirements of large energy users (LEUs) in terms of connection policies and infrastructure development. It would also include highlighting the necessary infrastructure investments to support the connection and integration of LEUs. This includes upgrading existing infrastructure and developing new facilities to accommodate the increased demand from LEUs and addressing the security of supply concerns of LEUs.

We should ensure that the gas network can reliably meet the energy demands of large users, particularly during peak periods. Strategies should be incorporated to support the decarbonisation of the energy sector, including the integration of renewable energy sources such as Biomethane and Green Hydrogen. This aligns with the broader goals of reducing carbon emissions and promoting sustainability.

Demand flexibility and energy efficiency for LEUs should also be considered. This includes promoting measures that encourage LEUs in optimising their energy usage and reducing peak demand. Update the modeling and forecasts in the TYNDP to reflect the anticipated impact of the connection policies for LEUs. This includes adjusting demand projections and infrastructure requirements based on the expected growth and energy usage patterns of LEUs.

Summary

Achieving climate targets requires coordinated action and a clear roadmap for all stakeholders across both public and private sectors. Previous Climate Action Plans have been instrumental but have not resulted in adequate progress. The ultimate goal is to transition to a climate-resilient, biodiversity-rich, environmentally sustainable, and climate-neutral economy by 2050. Ireland lags behind its EU peers in reducing CO2 emissions due to inconsistent action in advancing infrastructure, underinvestment, planning issues, and regulatory uncertainty.

Substantial investment is needed for developing renewables like Biomethane and Hydrogen. Grants and financial incentives are crucial for stimulating growth in the biomethane sector. The government has allocated €40 million in capital grants for biomethane development, but higher levels of support will be needed. Chambers Ireland advocates for further development of Hydrogen as part of the national and EU Hydrogen Strategies. Significant investments in renewable hydrogen electrolysers and infrastructure are also required.

We must also ensure that Ireland remains fully attuned and open to improved technology, new developments and innovations in the field of energy generation.

1 The Chambers Ireland SDGs. Available at: https://chambers.ie/sustainable-development-goals/

2 https://www.cso.ie/en/releasesandpublications/ep/p-eii/environmentalindicatorsireland2024/greenhousegasesandclimatechange/#:~:text=In%202022%2C%20Ireland%20had%20the,EU27%20average%20of%207.5%20tonnes

3 https://www.epa.ie/news-releases/news-releases-2024/ireland-is-projected-to-exceed-its-national-and-eu-climate-targets.php

4 https://www.gov.ie/en/publication/79659-climate-action-plan-2024/

5 https://assets.gov.ie/263248/f982c10f-eca6-4092-a305-90000e5213ed.pdf

6 https://energy.ec.europa.eu/topics/eus-energy-system/hydrogen/key-actions-eu-hydrogen-strategy_en

https://chambers.ie/press-releases/planning-bill-marks-vital-step-towards-reform/

CRU Consultation on Gas Networks Ireland Ten Year Network Development Plan 2024 - Submissions

Primary tabs