Energy Bill

Written Evidence submitted by Renewable Energy Systems (EB 28)

RES is the UK’s largest independent renewable energy developer with interests in onshore wind, wave and tidal, offshore, solar, energy storage and demand-side response. Since developing our first onshore wind farm in Northern Ireland in the early 1990s, RES has subsequently developed and/or constructed 16 onshore wind farms totalling 229MW – equivalent to over 37% of Northern Ireland’s onshore wind capacity.

RES would like to raise a concern in relation to the Government’s proposed amendment to the Energy Bill which specifies restrictions on the use of Northern Ireland Renewable Obligation Certificates within Great Britain.

While energy is a devolved matter, the punitive measures in new clause three (32LM) are likely to damage investor confidence in Northern Ireland. With the absence of legislation in Northern Ireland to bring about the closure of the Northern Ireland Renewables Obligation to onshore wind and without the policy intent and context, this clause has a resulting disproportionate impact on the economy in Northern Ireland.

The Energy Bill provides context in the form of eligibility and grace period provisions for England, Wales and Scotland. In the absence of legislation in Northern Ireland, the recent inclusion of new clause three (32LM) will see the creation of two ‘classes’ of NIROC and a format of NIROC that is untradeable with Great Britain. This clause, without context or further information, is scaring investors off in not just new projects that are consented and under construction but existing operational wind farms in Northern Ireland.

To help alleviate this issue we strongly advocate the inclusion within the Energy Bill of a reference to the "equivalent terms" on which DECC and DETI agreed to the closure of the NIRO, and were published by DETI in September 2015.

Our amendment is as follows (our proposed text in bold):

(2) A "relevant Northern Ireland certificate" is a Northern Ireland certificate issued in respect of electricity generated-

(a) after 31 March 2016 (or any later date specified in the regulations), and

(b) by a Northern Ireland onshore wind generating station accredited after 31 March 2016 (or any later date specified in the regulations), which

( i ) is a 33kV connected onshore wind generating station consented after 30th September 2015, or

(ii) a cluster connected onshore wind generating station consented after 31st October 2015.

We hope you find our recommendation helpful and please do not hesitate to contact me should you have any questions.

February 2016

 

Prepared 3rd February 2016