ISI-088 Complete Submission To DCENR On Solar Renewable Energy, Rev B, Final, 18-Sep-15

Environmental Management Services
Comhairleoirí Comhshaoil
Environmental and Planning Consultants
Submission)to)the)Department)of)
Communications,)Energy)and)Natural)Resources)
)
)
)
P HOTOVOLTAIC) S OLAR) E NERGY)AS)AN) A PPROPRIATE)
T ECHNOLOGY)FOR)THE) S UPPLY)OF) E LECTRICITY)FROM)
A) C ONTINUOUSLY) R ENEWABLE) R ESOURCE )
18)September)2015)
Outer Courtyard, Tullynally, Castlepollard, County Westmeath

Clós Seachtrach, Tulaigh an Eallaigh, Baile na gCros, Co. an Iarmhí
Telephone 044 966 2222 Fax 044 966 2223 E-mail jackosullivan2006@gmail.com

18#September#2015#
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Decarbonisation#Division,##
Department#of#Communications,#Energy#and#Natural#Resources,##
29B31#Adelaide#Road,##
Dublin#2.#
By#email#to:#ress@dcenr.gov.ie#
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Dear#Sir,#
#
Submission)to)the)Department)of)Communications,)Energy)and)Natural)Resources)on)
Solar)Energy)as)an)Appropriate)Technology)for)the)Supply)of)Electricity)from)a)
Continuously)Renewable)Resource)
#
In# response# to# the# Department’s# Renewable# Electricity# Support# Scheme# Technology#
Review#Consultation,#2015,#Environmental#Management#Services#welcomes#this#public#
consultation,#and#we#are#pleased#to#have#the#opportunity#of#making#a#submission.#
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The#primary#purpose#of#our#submission#is#to#demonstrate#that#renewable#generation#
of# electricity# by# solar# PV# has# the# appropriate# characteristics# to# make# a# major#
contribution# to# Ireland’s# transition# from# a# largely# fossil# fuel# based# economy# to# one#
based#on#renewable#energy,#to#improve#energy#security,#and#to#assist#in#meeting#the#
targets#and#challenges#identified#in#the#Department’s#consultation#document.###
#
We# also# hope# that# the# Department# will# take# appropriate# steps# to# ensure# that# the#
advantages# of# solar# photovoltaic# electricity# are# widely# and# fully# understood# and#
appreciated,# and# that# this# technology# will# take# its# place# among# other# sources# of#
renewable# energy# in# Ireland.# # In# order# to# achieve# this# aim,# we# believe# that# DCENR#
should#embark#on#a#proactive#public#awareness#campaign#to#clearly#demonstrate#the#
benefits#of#solar#PV#energy.#
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Lastly,#and#of#the#greatest#importance,#we)urge#the#Department#of#Communications,#
Energy# and# Natural# Resources# to# expedite# the# introduction# and# implementation# of# a#
competitive# solar# PV# Renewable# Energy# FeedBin# Tariff# (REFIT),# so# as# to# benefit# smallB
scale,# mediumBscale# and# largeBscale# producers.# # We# believe# that# this# is# essential# to#
make# solar# PV# electricity# more# competitive,# would# help# to# increase# the# amount# of#
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Submission by Environmental Management Services to the
Department of Communications, Energy and Natural Resources
solar# PV# installed,# and# would# generate# more# examples# to# further# demonstrate# the#
technology’s#financial,#social#and#environmental#advantages.##
#
We#consider#that#the#difference#in#policy#and#practice#between#the#Republic#of#Ireland#
and# Northern# Ireland# in# relation# to# the# availability# of# a# feedBin# tariff# constitutes# a#
distortion#of#the#market#for#solar#PV,#and#it#is#hard#to#understand#the#reason#for#this,#
given# that# a# single# electricity# market# has# operated# since# 2007,# with# wholesale#
electricity#prices#being#determined#on#an#AllBIreland#basis.##We#would#therefore#urge#
DCENR#to#level#this#“playing#field”,#so#that#a#similar#business#case#could#be#made#for#
investment#in#solar#PV#on#either#side#of#the#border.#
#
An# electronic# copy# of# our# submission# is# attached,# and# we# trust# that# DCENR# will#
consider#the#above#brief#points#in#this#covering#letter#as#part#of#our#overall#submission;#
and#we#look#forward#to#the#Energy#Policy#White#Paper#in#due#course.#
#
Yours#sincerely,#
#
Jack#O’Sullivan#

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ISIB087#Letter#to#DCENR#with#submission#on#solar#renewable#energy,#Rev#B,#18BSeptB15.docx#
2
Submission to the Department of Communications, Energy and

Natural Resources on Photovoltaic Solar Energy as an
Appropriate Technology for the Supply of Electricity from a
Continuously Renewable Resource
CONTENTS
Page
1. Introduction .. .. .. .. .. .. .. .. .. 1
2. The background to solar photovoltaic energy .. .. .. .. 4
3. Availability of solar irradiation in Ireland .. .. .. .. .. 6
4. Increasing efficiency and declining costs of Solar PV .. .. .. 10
5. Planning and development control issues .. .. .. .. .. 14
6. Solar energy installations, biodiversity and agriculture .. .. .. 15
7. The case for financially supporting solar PV electricity .. .. .. 16
8. Public perception, awareness raising and acceptability .. .. .. 18
9. Conclusions and recommendations .. .. .. .. .. .. 19
Figures
Figure 3.1 Annual amounts of solar irradiation across Europe, measured in

kWh/m2, on optimally inclined south-oriented photovoltaic modules
and the annual amounts of solar electricity generated by optimally
inclined 1kW systems with a performance rating of 0.75 .. .. 7
Figure 3.2 Annual amounts of solar irradiation on a horizontal surface,
measured in kWh/m2, across the UK and Ireland .. .. .. 8
Figure 3.3 Comparison between amounts of solar irradiation falling on Spain,
Germany and Ireland .. .. .. .. .. .. .. 9
Figure 4.1 Increasing solar PV cell efficiencies year-on-year, obtained under
laboratory conditions .. .. .. .. .. .. .. 11
Figure 4.2 Cumulative production and the associated reduction in price of solar
photovoltaic modules .. .. .. .. .. .. .. 12
Figure 4.3 Wholesale prices of 1.0Wp Chinese manufactured crystalline PV
modules, from mid 2010 to 2014 .. .. .. .. .. 13
ISI-086 Contents pages of Submission to DCENR on Solar Renewable Energy, Rev B, 18-Sep-15.doc
(i)

Submission to the Department of Communications,

Energy and Natural Resources on Photovoltaic
Solar Energy as an Appropriate Technology for the
Supply of Electricity from a Continuously
Renewable Resource
Submitted in response to the Department’s Renewable Electricity
Support Scheme Technology Review Consultation, 2015
18 September 2015
1. I NTRODUCTION
In July 2015, the Department of Communications, Energy and Natural Resources
issued a consultation document1 for the purpose of seeking views on the available
technologies for the generation of electricity from renewable resources, the cost-
effectiveness of these technologies, and the level of Government financial and
other support required to ensure an adequate and appropriate level of uptake.
The consultation is part of a wider process aimed at the development of a new

support scheme from 2016 onwards, for electricity generated from renewable
resources, and to contribute to the forthcoming Energy Policy White Paper, to be
published in October 2015. The new support scheme will also take into account
the results of the public consultation on the Green Paper on Energy Policy which
was published in May 2014.
1
Renewable Electricity Support Scheme -- Technology Review Consultation. Department of
The importance of renewable sources of energy has previously been emphasised

in the Strategy for Renewable Energy 2012 – 2020 2 , which stated that the
development of renewable energy is central to overall energy policy in Ireland:
“renewable energy reduces dependence on fossil fuels, improves security of
supply, and reduces greenhouse gas emissions creating environmental benefits
while delivering green jobs to the economy, thus contributing to national
competitiveness and the jobs and growth agenda”.
The Strategy for Renewable Energy identified five strategic goals:

• Generating more renewable electricity from onshore and offshore wind
power for the domestic and export markets;
• Building a sustainable bioenergy sector supporting renewable heat,
transport and power generation;
• Fostering research and development of renewable technologies including
wave and tidal;
• Increasing sustainable energy use in transport through the use of biofuels
and electrification; and,
• Building an intelligent, robust and efficient electricity network system.
The Strategy failed to mention solar photovoltaic, and placed great emphasis on
the utilisation of wind power.
Other over-arching determinants of Ireland’s renewable energy policy include the

2009 EU Renewable Energy Directive, under which Ireland has been given a
legally binding target of meeting 16% of the country’s energy requirements from
renewable sources by 2020. Ireland is committed to meeting 40% of electricity
demand from renewable sources, as well as 12% in heat and 10% in transport.
More recently, at the European Council meeting on 23 and 24 October 2014,

agreement was reached on Europe Union targets for the Climate and Energy
Policy Framework3, including:4
i) a binding EU target of at least 40% reduction in greenhouse gas emissions
by 2030, compared to 1990;
ii) an EU target of at least 27% for the share of renewable energy consumed in
2
Strategy for Renewable Energy: 2012 – 2020. Department of Communications, Energy and
Natural Resources.
3
European Commission, 2014. Communication from the Commission to the European
Parliament, the Council, the European Economic and Social Committee and the Committee of
the Regions: A Policy Framework for Climate and Energy in the Period from 2020 to 2030.
COM(2014) 15 final; Brussels, 22.1.2014.
4
European Council Conclusions, Brussels, 24 October 2014; EUCO 169/14 (Note from the
General Secretariat of the Council, to Delegations).
18 September 2015 Page 2 of 22

the EU in 2030; this target will be binding at EU level, and must be fulfilled
through Member States contributions guided by the need to deliver
collectively the EU target without preventing Member States from setting
their own more ambitious national targets; and,
iii) an indicative target of at least 27% increase in energy efficiency by 2030.
In Ireland, the Department’s Technology Review Consultation document notes that

these targets will require emissions reductions of 43% and 30% respectively over
the 2005 levels for participants in the Emissions Trading Scheme (ETS) and for the
non-ETS sectors. The document observes that “while good progress has been
made to date, our 2020 targets continue to be challenging”, and “regulatory
certainty is needed to provide the platform for promoters to continue to access
funding and progress their projects”.5
Looking to the very near future, EU environment ministers will meet in Brussels on
Friday 18 September, after which they are expected to announce that the EU will
press for targets of a global 60% emissions cut by 2050, and 100% emissions
reduction by 2100, despite the initial objections of Poland, Hungary, and the Czech
Republic. Agreement among Member States is needed to ensure that EU
negotiators can push for a strong international framework to limit global warming to
no more than two degrees higher than pre-industrial levels. The proposed
emission cuts will have to be soundly based and defended, in order to increase the
probability of securing a legally binding cap on global warming at the United
Nations Climate Change Conference (COP21) in Paris in November.
It is therefore clear that not only are the agreed emission reduction targets quite
challenging, but that more serious challenges lie ahead in order to reduce and
eventually eliminate dependency on fossil fuels as our principal source of energy.
These critical issues are clearly recognised by the Minister for Communications,
Energy and Natural Resources, Mr Alex White, T.D., in his address to the
conference on Ireland’s Energy Transition, at Dublin Castle,6 on 03 June 2015,
when he stated that:
“The impact of global warming demands that we put sustainability at

the very centre of our energy policy. The scale of the challenge was
starkly outlined in the report of the Intergovernmental Panel on Climate
Change, which informed the Lima conference. It is now absolutely
clear that the world must replace gas and coal with renewable energy
sources within 35 years.
5
Renewable Electricity Support Scheme -- Technology Review Consultation; Introduction,
paragraphs 1.2 and 1.3. Department of Communications, Energy and Natural Resources, July
2015.
6
http://www.dcenr.gov.ie/news-and-media/en-ie/Pages/Speech/Alex-White-Minister-for-
Communications-Energy-and-Natural-Resources-Irelands-Energy-Transition.aspx

Our vision here must be equally clear and equally ambitious. We must
and we will transform Ireland’s energy production and consumption
patterns so that, by 2050, our system will be largely decarbonised.
This vision comes with a pledge to all our citizens, our communities,
industry, and those who work to provide energy to our homes and
workplaces that policy will ensure certainty, stability and affordability,
as we make the transition to a low carbon future”.
When referring to renewable sources of electricity, the Minister stated that:
“Onshore wind has so far been at the centre of Ireland’s renewable

energy generation. It has served us well, and it will continue to do so.
But the next period of energy transition will also see the development
of new commercial and late-stage solutions, which are likely to change
the mix of renewables as technologies like solar PV [our emphasis],
off-shore wind, and carbon capture and storage mature, and become
more cost-effective”.
The Minister’s reference to solar PV is most welcome, and provides an additional

basis for our submission that solar photovoltaic can be a very significant source of
electricity for Ireland’s future needs. In this submission, Irish Solar Innovations
hopes to demonstrate that solar PV possesses appropriate characteristics to make
a major contribution to Ireland’s transition from a largely fossil fuel based economy
to one based on renewable energy, and to assist in meeting the targets and
challenges mentioned above. We are pleased to have the opportunity of making a
submission, and look forward to the Energy Policy White Paper in due course.
2. T HE B ACKGROUND TO S OLAR P HOTOVOLTAIC

E NERGY
Power generation from solar photovoltaic has long been recognised as a clean
sustainable energy technology which draws upon the planet’s most plentiful and
widely distributed renewable energy source – the sun. The direct conversion of
sunlight (or daylight, as solar PV does not need direct sunlight) to electricity occurs
without any moving parts or environmental emissions during operation. It is well
proven, as photovoltaic systems have now been used for fifty years in specialised
applications, and grid-connected PV systems have been in use for over twenty
years. They were first mass-produced in the year 2000, when German
environmentalists succeeded in obtaining government support for a programme
which resulted in more than 100,000 roofs being fitted with solar PV panels.
Driven by advances in technology and by increases in manufacturing scale and

sophistication, the cost of solar photovoltaic energy has declined steadily since the

first solar cells were manufactured, and the levelised cost7 of electricity from PV is
now competitive with conventional electricity sources in an expanding list of
geographic regions. Net metering and financial incentives, such as preferential
feed-in tariffs for solar-generated electricity, have supported solar PV installations
in many countries. With current technology, photovoltaic systems recoup the
energy needed to manufacture them in 1.5 to 2.5 years in Southern and Northern
Europe, respectively.
Mass production has been the principal key to reducing costs and gaining
competitiveness; historically, PV was an expansive technology, partly because, for
a long time, its key market was extremely small and restricted to applications in
space where the main criterion is weight rather than cost. Intervention by
governments has been indispensable in providing the necessary impetus to get out
of the vicious circle of “no market – no mass production – no market”.
Government financial support was first tried in Germany and Japan for what were
described as “PV roof programmes”; with the first such programme being initiated
in Bonn by the German Research Ministry; it financed 2,200 PV roofs, beginning in
1989. From 1994, a similar programme was conducted by the Japanese. A new
German 100,000 PV Roof Programme ran from 2000 until 2003; it was actually a
300-MW PV programme that included a “zero interest rate credit” and a 12.5%
subsidy. The purpose of the Feed-in-Tariff (FIT) subsequently applied was to
strengthen the 100,000 PV Roof Programme and enhance its productivity.
Solar PV is now, after hydro and wind power, the third most important renewable
energy source in terms of globally installed capacity, with more than 100 countries
using solar PV. Installations may be ground-mounted (and sometimes integrated
with farming and grazing) or built into the roof or walls of a building (either building-
integrated photovoltaics or simply rooftop).
In 2014, worldwide installed PV capacity increased to at least 177 gigawatts (GW),

sufficient to supply 1.0% of global electricity demands. Due to the exponential
growth of photovoltaics, installations are rapidly approaching the 200 GW mark –
about 40 times the installed capacity of 2006. China, followed by Japan and the
United States, is the fastest growing market, while Germany remains the world's
largest producer, with solar contributing about 7% to its annual domestic electricity
consumption.
7
The levelised cost of electricity (LCOE) is a measure which attempts to compare different
methods of electricity generation on a comparable basis. It comprises an economic assessment
of the average total cost to build and operate a power-generating asset over its lifetime divided
by the total power output of the asset over that lifetime. The LCOE can also be regarded as the
cost at which electricity must be generated in order to break-even over the lifetime of the
generating plant or installation.

3. A VAILABILITY OF S OLAR I RRADIATION IN I RELAND

While it is commonly believed that the Irish weather limits the potential of solar
power, the amount of solar radiation in Wexford is around 78% of the level enjoyed
in Madrid, and is equivalent to the levels found in most areas of Britain, a country
which has successfully deployed 4,460 MW of solar electricity in the past 5 years.8
As far back as 1975, in the aftermath of the large increase in oil prices during 1973
and 1974, the National Science Council undertook a number of research projects
on renewable energy sources, one of which examined solar energy. The project
report, written by Eamon Lalor 9 , concluded that the amount of available solar
energy in Ireland was, on a per-head-of-population basis, the same as in France.
A surprising conclusion perhaps, but the author of this submission remembers
clearly the results obtained by Eamon Lawlor, and the unfortunate fact that when
oil prices stabilised, the research project was terminated, and the proposed
research programme was never carried out.
More recently, a report by IBM and the City of Dublin Energy Management Agency
(CODEMA) pointed out that “the amount of daylight, or the solar irradiance, Dublin
receives is approximately the same as that received in Leipzig, Germany, home of
one of the world’s largest solar electricity plants, Waldpolenz Solar Park.”10 The
report also concluded that “Solar PV energy is a viable power strategy due to its
scalability, its easy deployment and the abundant availability of solar radiation.”
The map in Figure 3.1 shows the photovoltaic solar electricity potential in Europe,
and it is clear that Ireland is not particularly disadvantaged; in fact the amount of
solar irradiation (measured in kWh/m2) falling on Ireland is only slightly lower than
in France, and very close to that in Germany. The south-east of the country gets
more sun than the west and north-west, but the map surprisingly shows the
extreme north of the country to be the least favoured.
The submission by the Irish Solar Energy Association to the public consultation on
the Green Paper on Energy Policy in Ireland, to which we have referred above,
also includes a map of solar irradiation across Ireland and Britain, which gives a
more detailed view of the different levels of solar energy available, confirming the
similarity between most of Ireland and the central and south-eastern areas of
England (see Figure 3.2 below).
8
Submission by the Irish Solar Energy Association to the Consultation on the Green Paper on
Energy Policy in Ireland, 31 July 2014. Available from http://irishsolarenergy.org/wp-
content/uploads/2014/09/ISEA-Green-Paper-on-Energy-Policy-in-Ireland.pdf
9
Lalor, Eamon, 1975. Solar Energy for Ireland: a Preliminary Analysis of the Basic Data with
Tentative Proposals for a Programme of Research and Development : Report to the National
Science Council. Dublin : National Science Council; Government Publications Sale Office, 1975.
10
Dublin – Smarter Cities Challenge Report. IBM Corporation, 2015.

2
Figure 3.1 Annual amounts of solar irradiation across Europe, measured in kWh/m , on
optimally inclined south-oriented photovoltaic modules (left-hand scale) and
the annual amounts of solar electricity generated by optimally inclined 1kW
systems with a performance rating of 0.75.

Figure 3.2 Annual amounts of solar irradiation on a horizontal surface, measured in

2
kWh/m , across Britain and Ireland. From Commission of the European
Communities, Joint Research Centre.
This map shows that nearly all of Munster and the southern half of Leinster have
better levels of solar irradiation than the northern and north-western parts of the
country. Despite these differences, the ISEA report observes that in the North of
Ireland, the feasibility of solar power has been demonstrated by the fact that the
first planning permission for a large utility-scale solar farm in Ireland was granted in
Bishopscourt, County Down in early 2014. The reasons for this will become clear
when we examine the different levels of support given to solar power installations
by the two jurisdictions in Ireland.
A presentation by Paul Dykes (SEAI) at a conference held in Johnstown Castle on

11 May 2011, provides data similar to that in Figure 3.1. He states that the
average solar irradiation in Ireland is between 2.5 and 3.0 kWh/m2 per day, or 910-
1100kWh/m2 per year; i.e., an area the size of a football pitch would receive the

energy equivalent of 2,500 litres of oil per day, or enough energy to power a 60W
light bulb continuously for 46 years!
Paul Dykes, in the same presentation, shows that Ireland has only 6% less solar
irradiation per unit area than Germany, but while Germany has 44% of the market
share of solar energy, Ireland has less than 5% (see Figure 3.3 below). The stark
contrast between the two countries forces us to ask why Ireland is lagging so far
behind in the utilisation of solar energy, and it should become clear that the
principal reason is the lack of Government support for PV technology in Ireland.
Figure 3.3 Comparison between amounts of solar irradiation falling on Spain, Germany
and Ireland: Spain receives 26% more solar energy per unit area than Ireland,
while Germany receives only 6% more. Figure adapted from a presentation
by Paul Dykes, SEAI, given at a conference held in Johnstown Castle on 11
May 2011.

4. I NCREASING E FFICIENCY AND D ECLINING C OSTS OF

S OLAR PV
Numerous attempts to cut down the costs of PV cells and modules to the point
where they are both competitive and efficient have brought amazing results, mainly
achieved by significantly increasing the conversion efficiency of PV materials.
In order to increase the efficiency of solar cells, it is necessary to choose the

semiconductor material with appropriate energy gap that matches the solar
spectrum. This will enhance their electrical, optical, and structural properties.
Choosing a better approach to get more effective charge collection is also
necessary to increase the efficiency. There are several groups of materials that fit
into different efficiency regimes. Ultrahigh-efficiency devices (η>30%) are made by
using GaAs and GaInP2 semiconductors with multijunction tandem cells, and high-
quality, single-crystal silicon materials are used to achieve high-efficiency cells
(η>20%).
The recent development of organic photovoltaic cells (OPVs) has greatly advanced
power conversion efficiency from 3% to over 15%. To date, the highest reported
power conversion efficiency ranges from 6.7% to 8.94% for small molecule, 8.4%–
10.6% for polymer OPVs, and 7% to 15% for perovskite OPVs. Not only are these
recently developed OPVs more efficient and low-cost, they are also more
environmentally benign and made of raw materials from renewable renewable.
According to a recent report by the Fraunhofer Institute11:

• The record lab cell efficiency is 25.6 % for mono-crystalline and 20.8 % for
multi-crystalline silicon wafer-based technology. The highest lab efficiency in
thin film technology is 21.0 % for CdTe and 20.5 % for CIGS solar cells.
• In the last 10 years, the efficiency of average commercial wafer-based
silicon modules increased from about 12 % to 16 %. At the same time, CdTe
module efficiency increased from 9 % to 13 %.
• In the laboratory, best performing modules are based on mono-crystalline
silicon with about 23 % efficiency. Record efficiencies demonstrate the
potential for further efficiency increases at the production level.
• In the laboratory, high concentration multi-junction solar cells achieve an
efficiency of up to 46.0 % today. With concentrator technology, module
efficiencies of up to 38.9 % have been reached (see Figure 4.1 below).
11
Fraunhofer Institute, 2015. Photovoltaics Report: Prepared by the Fraunhofer Institute for Solar
Energy Systems ISE with support of PSE AG. Freiburg, 26 August 2015. www.ise.fraunhofer.de

Figure 4.1 Increasing solar PV cell efficiencies year-on-year, obtained under laboratory
conditions. Figure adapted from the Fraunhofer Institute report cited above.
It is worth pointing out that the high efficiency obtained from multi-junction
concentrator solar cells with multiple p–n junctions made of different semiconductor
materials could further increase as a result of continuing technical development.
Each material's p-n junction will produce electric current in response to different
wavelengths of light, and the use of multiple semiconducting materials allows the
absorbance of a broader range of wavelengths, improving the cell's sunlight to
electrical energy conversion efficiency. Traditional single-junction cells have a
maximum theoretical efficiency of 34%. Theoretically, an infinite number of
junctions would have a limiting efficiency of 86.8% under concentrated sunlight.
As a result of these significant advances in technology, together with mass

production of solar PV modules, their price has declined significantly over the last
decade, dropping from around €1.5/kWp in 2010 to currently less than €0.6/kWp
and is set to decline even further.
The submission by the Irish Solar Energy Association to the Consultation on the
Green Paper on Energy Policy in Ireland, cited above, states that:
“ … the costs of solar modules in Europe have fallen by 42% since 2011
from €0.96/w to €0.56/w. This contrasts heavily with energy prices in
Ireland, which have increased by 27% in the same period. From a solar
resource perspective, the cost reduction means that €1,000 invested in a
solar project in Greece in 2011, will generate the same amount of electricity
as €1,000 invested in a solar project in Athlone in 2014. Looking forward,
installation costs for solar are projected to continue to fall a further 29% from
€1.03/w in 2014 to €0.73/w by 2020. This will make solar a cheaper source
of renewable energy than onshore wind, with grid parity expected no later
than 2025”.

These price reductions in solar PV have also been noted by the Deutsche Bank in
a report on the solar power industry. The report states that the bank expects solar
electricity to become competitive with retail electricity in an increasing number of
markets globally, due to declining solar panel costs as well as improving financing
and customer acquisition costs. Unsubsidised rooftop solar electricity costs
between US$0.08 and $0.13/kWh, 30-40% below retail price of electricity in many
markets globally. In markets dependent on coal for electricity generation, the ratio
of coal-based wholesale electricity to solar electricity cost was 7:1 four years ago.
The ratio is now under 2:1 and could approach 1:1 over the next 12-18 months.12
The Deutsche Bank report also observes that the economics of solar PV energy
have improved significantly due to the reduction in solar panel costs, financing
costs and balance of system costs. Overall solar system costs have declined by
approximately 15% compound annual growth rate over the past 8 years and the
bank expects another 40% cost reduction over the next 4-5 years.
Figure 4.2 Cumulative production and the associated reduction in price of solar
photovoltaic modules.
12
Deutsche Bank Markets Research, 2015. The Solar Industry: FITT for Investors – Crossing the
Chasm; 27 February 2015.

Mass production must not be forgotten as a significant factor in helping to lower the
price of solar PV. The report by the Fraunhofer Institute provides an illustration
showing how every time the cumulative production of electricity from solar PV has
double, the price went down by 19.6% (inflation adjusted €/Wp) (see Figure 5.2
above).13 Figure 4.3 below shows how the wholesale prices of 1.0Wp Chinese
manufactured crystalline PV modules have declined from mid 2010 to 2014.
Figure 4.3 Wholesale prices of 1.0Wp Chinese manufactured crystalline PV modules,

from mid 2010 to 2014. From AES Europe GmbH, Clean Energy Investment;
http://www.europe-solar.de/catalog/images/solar/price-trend-modules-h.jpg
Largely as a result of these economic and technical changes, the market for
photovoltaics is fast growing; and the Compound Annual Growth Rate (CAGR) of
PV installations was 44 % between 2000 and 201414.
According to a recent Communication from the European Commission15, a large

and stable market, combined with coordinated research and innovation and scaled
up manufacturing, can achieve further cost reduction of key renewable
13
14
15
European Commission, 2015. Communication from the Commission -- Towards an Integrated
Strategic Energy Technology (SET) Plan: Accelerating the European Energy System
Transformation. Brussels, 15.9.2015 C(2015) 6317 final.

technologies. Regional cooperation where there is common renewable energy

potential can help achieve further cost reductions, in particular for:
• offshore wind energy systems, including deployment and maintenance
technologies and techniques, and the associated grid systems;
• ocean energy; and,
• photovoltaic and solar thermal systems, algae and biomass residues.
There is no doubt, from the information we have provided above, that solar PV
materials and modules are becoming more efficient and cheaper, and that
efficiencies will continue to increase, and prices will become lower. Whether a
shortage of raw materials will slow down this trend is unknown, but in the
immediate future the competitiveness of solar PV for electricity generation will
improve, to the stage where it is now becoming less costly to generate electricity
from solar PV than from other renewable resources such as wind or biomass.
Nevertheless, it is our submission that in order to accelerate the uptake of PV
systems in Ireland, appropriate State funding is needed in the form a Renewable
Energy Feed-in Tariff (REFIT) or other financial support. Only with the assistance
of such measures will Ireland be able to make use of the abundant solar energy
available.
5. P LANNING AND D EVELOPMENT C ONTROL I SSUES
A further advantage of solar PV over other renewable sources of electricity (e.g.,

wind, anaerobic digestion, methane from landfills) is the rapidity with which solar
can be deployed. Planning and consultation processes are significantly shorter
than for other electricity generation technologies, while construction is extremely
rapid, with a single team able to install 1 – 2MW of capacity per week on large
scale solar farms. In addition, the modular nature of solar PV means that plant
sizes can be adapted to local conditions, and capacity can be distributed over a
wider area.
In Ireland, there is plenty of suitable land on which to roll out large scale solar
projects, particularly marginal agricultural land and cutaway bogs that are no longer
suitable for peat cutting. Solar farms can also be implemented across a wide
variety of platforms, such as commercial rooftops and former landfill sites. The
latter could be particularly suitable, as these sites are usually free of heavy
vegetative growth, they support only grasses and other small plants, grazing and
tree growth is not permitted, and there are few other suitable uses available or
permitted. However, care would have to be taken to ensure that the impermeable
cover beneath the topsoil layer would not be damaged by the installation of
ground-based PV systems.

Ground-based PV systems do not create the same visual impact as other

renewable energy facilities, e.g., wind farms. The structures supporting the PV
panels are relatively unobtrusive at ground level, being less than 2.5m in height,
below the level of most hedgerows in Ireland, and therefore having minimal visual
impact. The absence of moving parts results in an almost noise-free electricity
generating plant, and the solar PV arrays are temporary structures, which may be
removed after a period of around 20 to 25 years, after which the land can be
restored to its original condition. Heavy foundations or large areas of concrete are
not needed, and powerful cranes are not needed to place the solar arrays and
supporting structures in position.
Other potential sites include roofs of commercial buildings, sports facilities, and
industrial plants. Obtaining planning permission for roof-mounted PV installations
should not be difficult.
In contrast, other renewable energy sources, particularly wind farms and anaerobic
digestion facilities, have attracted significant objections, leading to delays in
securing planning permission, appeals to An Bord Pleanála, and (in a number of
recent cases) applications to the High Court to Judicially Review decisions by An
Bord Pleanála.
6. S OLAR E NERGY I NSTALLATIONS , B IODIVERSITY AND

A GRICULTURE
Solar farms present an excellent opportunity to protect, and even to enhance, local
biodiversity. In most solar farms, the panels are set on piles and there is minimal
disturbance to the ground. The panels have no moving parts and the infrastructure
typically disturbs less than 5% of the ground. The posts on which the panels are
mounted take up less than 1% of the land area; and normally only 25-40% of the
ground surface is over-sailed by panels.
Because panels are raised above the ground on posts, more than 95% of the land
utilised for solar farm development is still suitable for plant growth, and potentially
for wildlife and agricultural activities such as light to moderate grazing. Following
construction and commissioning, there is very little need for human activity on site,
apart from occasional maintenance visits.
Most sites have a lifespan of at least 20 years which is sufficient time for
appropriate land management practices to yield wildlife benefits.
A number of options exist for enhancing biodiversity on solar farms, including

hedgerows, field margins, wild flower meadows, bird boxes and ponds. Each site
is unique and there is no ‘one size fits all’ solution. Ultimately the best plans will be

those developed through engagement with the local community, the landowner and
local and national conservation organisations.
One possibility which offers great potential, but which needs to be examined
carefully, is the use of worked-out peatlands as locations for large scale solar
farms. While these areas are generally fairly level and may have few other uses,
there are ecological considerations which must be taken into account. In recent
years, worked-out bogs have been suggested as suitable areas for wind-farming,
but such developments require construction of roads capable of accommodating
heavy and lengthy transport vehicles, the creation of areas of hard-standing for use
by cranes and other construction equipment, and the emplacement of large and
heavy concrete bases to support the turbine towers; all of which have adverse
effects on drainage and ecology.
Provided that sufficient care is taken to prevent damage to the remaining peat
layer, solar PV farms could relatively easily be developed on former bogs where
further peat harvesting is not possible or has been discontinued for environmental
reasons. The use of light construction materials and temporary surface protection
could enable installation of PV solar arrays to proceed without significant ecological
damage.
In some locations, it may even be possible to undertake restoration of the peatland

habitat during the lifetime of the solar farm, though we have no information yet
about how peatland vegetation would re-grow in the shaded conditions under the
solar panels. Restoration to former ecological conditions requires infilling or
blocking former land drains dug to allow peat harvesting when the bog was in
active use. Blocking of drains and re-wetting of the peatland to be restored is
required, so that water levels will rise, to allow re-colonisation by Sphagnum.
Maintenance of the solar farm under such conditions might be more difficult, but it
is not inconceivable that specialised equipment would be developed to allow
occasional inspection and maintenance to be carried out without causing
ecological damage.
7. T HE C ASE FOR F INANCIALLY S UPPORTING S OLAR

PV E LECTRICITY
The Republic of Ireland does not currently have a renewable energy feed-in tariff
(REFIT) for solar energy. The unfortunate result of this lack of financial support is
that, unlike other countries, there is not a strong business case in Ireland for
generating electricity from solar PV and selling it back to the grid because the
financial return is not favourable.
This situation adversely impacts the type of business case that companies such as
ISI Ltd can make for solar PV in Ireland. Rather than installing PV with the

intention of selling the electricity using a REFIT, the most-effective business case
we can make for solar PV has to be based on local use, where all electricity
produced is used by the building or site where it is generated.
Grants are available to support renewable installations that include solar

technology, such as those from the Sustainable Energy Authority of Ireland (SEAI),
but these are unlikely to cover the full cost. However, there are significant
opportunities to leverage private financial contributions via power purchase
agreements (PPA) and other investment options, such as community funding.
One approach that has worked well in County Tipperary is to call for tenders based
on a target cost of energy per watt generated. So, rather than tender for a certain
area of solar panels with a given capacity, suppliers could be asked to tender
based on an expected cost in Euro per kWh of electricity produced. The tender
evaluation would then apply expert advice to assess the technical solution offered.
This helps the decision-making process because it allows for a more transparent
assessment of long-term costs and capital expenditures.
One further and very significant reason for introducing a renewable energy feed-in
tariff (REFIT) or similar financial support for solar energy is to level the “playing
pitch” between the Republic of Ireland and Northern Ireland. As the Department
will be aware, under the Renewables Obligation Order (Northern Ireland) 2009,
and the Renewables Obligation (Amendment) Order (Northern Ireland) 2014,
electricity exported by producers to the local grid will provide a financial return to
the producer.
The Northern Ireland Renewables Obligation (NIRO) is the main policy instrument
for incentivising renewable electricity generation in Northern Ireland, and is
administered by the Department of Enterprise, Trade and Investment (DETI). The
policy places a requirement on all electricity suppliers to provide proof to OFGEM
that a portion of their energy supply comes from renewable sources. They account
for this by supplying a number of Renewables Obligation Certificates (ROCs) to
OFGEM each year.
When a business or householder begins generating their own energy, they apply
for and are issued with ROCs based on the technology they are using and the
amount of energy they produce. These ROCs are tradable and are of value to the
energy suppliers, meaning they can be sold for additional income. This is the key
to the success of the NIRO scheme, which has boosted renewable energy
generation in Northern Ireland from 4 per cent in 2005 to 14 per cent in 2012.
Even though the scheme has worked well to date, it is intended that it will be
terminated in 2017 if the Renewables Obligation Closure Order (Northern Ireland)
2015 is approved by the Legislative Assembly. This Statutory Instrument states
that no renewables obligation certificates are to be issued under a renewables
obligation order for electricity generated after 31st March 2017. In the meantime,

until the Order is approved, or fails to be approved, there is considerable

uncertainty about whether or not ROCs will continue to be issued after the cut-off
date of 31 March 2007.
As the Department will be aware, the All-Ireland electricity market has operated
since 01 November 2007 as a single electricity market (SEM), trading wholesale
electricity in the Republic of Ireland and Northern Ireland on an All-Ireland basis,
and managed by the Single Electricity Market Operator (SEMO). SEMO is a joint
venture between EirGrid plc (the transmission system operator for the Republic of
Ireland) and SONI (the System Operator for Northern Ireland), the latter being a
wholly owned subsidiary of Eirgrid.
We consider that it is a distortion of the market that payment for electricity exported
to the grid from PV installations is available to micro-generators in Northern
Ireland, while there is no similar payment available to the owners or operators of
similar installations in the Republic of Ireland. It is our submission that the “playing
field” should be levelled, and we see no reason why this cannot be done by
collaboration between the Commission for Energy Regulation (CER) in the
Republic of Ireland and the Authority for Utility Regulation in Northern Ireland
(NIAUR), through the Memoranda of Understanding (MoU) signed by these
agencies in August 2004 and June 2005, with the approval of both Governments.
8. P UBLIC P ERCEPTION , A WARENESS R AISING AND

A CCEPTABILITY
As we have seen from the widespread opposition to large-scale wind farms in
many parts of Ireland, support and engagement of the community is vital for
renewable energy projects to thrive, especially in rural areas. While most people
have generally positive attitudes towards solar energy, many do not fully
understand how it will benefit themselves, their commercial operations or their
communities, or why it is worth making the investment. We strongly advocate that
the Department should work with agencies such as the Sustainable Energy Agency
of Ireland (SEAI), and with environmental NGOs to build awareness of the value of
solar photovoltaic for electricity generation.
We have mentioned in section 2 above how German environmentalists succeeded

in persuading their government to support a programme which has now resulted in
Germany becoming a leader in the production and installation of solar PV panels.
In Ireland, the Action Plan by Friends of the Earth envisions a fossil fuel free
Ireland by 2050, and two of the most relevant objectives in the plan are:
• “Increase renewable generation with a target of 100% renewable heat and
electricity by 2040, and increase flexibility within these networks to
accommodate variable renewable supplies; and.

• Support solar electricity equally with other renewable technologies with a

feed in tariff or otherwise to ensure solar electricity generators get paid for
their power”.16
Ireland has clearly a long way to go in order to catch up with Germany and other
European countries, but the process will go more quickly and smoothly if a wide
range of stakeholders are engaged.
In seeking to develop large scale ground-based solar farms, we would suggest that
the lessons learned from attempts to impose industrial-scale wind farms on rural
populations must be taken into account. The Department will be acutely aware of
the wide-spread and strong public protest and concerted opposition to proposals
for the development of industrial wind farms in Ireland; and, while it is very likely
that solar farms would not attract any such opposition, it will be important to obtain
the support of local communities by means of proactive engagement and the
provision of information. Land is an emotive issue, and rural communities will need
to be convinced that this new land use would not be out of place in Ireland’s largely
agricultural landscape, or would not be detrimental to farming in general.
9. C ONCLUSIONS AND R ECOMMENDATIONS

Our principal conclusions and recommendations are:
Technology Cost: The price of solar PV modules has declined significantly over
the last decade, dropping from around €1.5/kWp in 2010 to
currently less than €0.6/kWp, and is set to decline even
further.
PV Efficiency: Solar PV is becoming increasingly more efficient at converting

ambient daylight and sunshine into electricity, and the current
level of efficiency will improve as a consequence of research
being undertaken in Europe and worldwide.
Risk Reduction: Solar PV is a low-risk and low-maintenance technology which

has demonstrated consistent performance. Other European
countries which have weather similar to Ireland, e.g., Germany
and Britain, as well as the North of Ireland, have successfully
implemented this technology.
Energy Security: Ireland is heavily dependant on imported fossil fuels (gas, oil
and coal) for electricity generation, and this constitutes a
significant risk to energy security at a time when the need to
16
Ireland needs an Energy Revolution – Friends of the Earth Action Plan, May 2015.

mitigate the worst effects of anthropogenic climate change are

at last being taken seriously; leading to much more
challenging emission reduction targets for greenhouse gases,
together with the likelihood that there will be greater
competition among nations for a decreasing availability of
fossil fuels, as the global campaign to leave some of these “in
the ground” gathers momentum. Diversification of indigenous
renewable energy sources is a therefore strategic priority for
Ireland, enabling the country to replace some imported energy
with a balance of renewables that are not dependent on a
single source.
Energy Efficiency: In addition to solar PV energy, Ireland’s energy policy and

strategy also must also embrace greater efficiency in energy
use, and should encourage smart building technologies
(including the proven “Passiv House” concept and standard
which can equally be applied to commercial and industrial
buildings), so as to reduce overall energy consumption and
increase the proportion of renewable energy sources in
comparison with non-renewable energy sources.
Local Energy: Photovoltaic installations are ideally suited to distributed

energy systems which allow generation and consumption to
occur in the same place, or at very short distances. This
approach reduces the cost of electricity transmission, which
can be an issue for other renewable energy sources;
especially large-scale wind farms, where the construction of
new high-tension power lines has caused planning and
environmental problems.
Environmental: Solar energy has low carbon dioxide and particulate emissions
per kWh generated; lower than other renewable energy
sources. Solar farms have not been found to have any
adverse effects on wildlife, and do not have to be located in
upland areas of wildlife importance; while roof-mounted solar
PV systems have no “land take” associated with them. This
situation contrasts with wind farms, which require the
construction of access roads, heavy foundations for the turbine
towers, risk to birds, and potential adverse effects on human
health.
Leadership: Ireland should seek to become a leader in the adoption of PV

solar electricity; and, while the country may not hope to reach
the levels of PV electricity generation achieved by Germany,
there is an opportunity for the country to demonstrate
leadership in renewable resources initiatives by using solar

energy to promote long-term benefits for industry, commerce,

and people.
Acceptability: There is an urgent need to raise public awareness of the value

and utility of PV-sourced electricity as an alternative to fossil-
fuelled power stations, and to large-scale wind farms which
have aroused so much hostility, planning objections, appeals
and High Court cases. In other countries where PV
installations are more numerous, people have expressed
positive reactions to them, but it will be important to keep
communities engaged and informed of the benefits and
advantages that solar power will bring. Doing so will help keep
people engaged and their attitudes positive, especially if
communities can take ownership of PV installations, perhaps
through innovative community funding arrangements. It is
therefore very important that the Department of
Communications, Energy and Natural Resources, acting
together with other departments and Agencies, should embark
on a proactive awareness campaign to clearly demonstrate the
benefits of solar PV energy.
Feed-in Tariff: The Department of Communications, Energy and Natural

Resources, acting together with the Commission for Energy
Regulation, should as a matter of urgency, and using its
influence with the Government and the Department of
Finance, press for and implement a solar PV renewable
energy feed-in tariff (REFIT) or similar financial support
measure, which would benefit solar energy and small-scale,
medium-scale and large-scale producers. This is essential to
make solar PV electricity more competitive, and would help to
increase the prevalence of solar PV, generating many more
examples to further demonstrate the technology’s financial,
social and environmental advantages.
Other Funding: We would also submit that multiple funding options for solar
PV should be explored and developed. These could include
direct finance from Government or local authorities (especially
where a community benefit can be demonstrated), asset-
based lending, partial or full funding through an energy service
company (ESCO), community and crowd-funding efforts.
N-S Integration: It is unnecessary and a distortion of the market that payment

(through the ROC system) for electricity exported to the grid
from solar PV installations is available to micro-generators in
the North of Ireland, while there is no similar or equivalent
payment available to similar installations in the Republic of

Ireland. It is our submission that the “playing field” should be

levelled, and we see no reason why this cannot immediately
be done by collaboration between the Commission for Energy
Regulation (CER) in the Republic of Ireland and the Authority
for Utility Regulation in Northern Ireland (NIAUR), through the
Memoranda of Understanding (MoU) signed by these
agencies in August 2004 and June 2005.
Jack O’Sullivan
September 2015
!
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Environmental Management Services

Outer Courtyard, Tullynally, Castlepollard, County Westmeath

Outer Courtyard, Tullynally, Castlepollard, County Westmeath

Environmental Management Services

Submission to the Department of Communications, Energy and

Figure 3.1 Annual amounts of solar irradiation across Europe, measured in

Outer Courtyard, Tullynally, Castlepollard, County Westmeath

Submission to the Department of Communications,

The consultation is part of a wider process aimed at the development of a new

The importance of renewable sources of energy has previously been emphasised

The Strategy for Renewable Energy identified five strategic goals:

Other over-arching determinants of Ireland’s renewable energy policy include the

More recently, at the European Council meeting on 23 and 24 October 2014,

18 September 2015 Page 2 of 22

In Ireland, the Department’s Technology Review Consultation document notes that

“The impact of global warming demands that we put sustainability at

18 September 2015 Page 3 of 22

When referring to renewable sources of electricity, the Minister stated that:

“Onshore wind has so far been at the centre of Ireland’s renewable

The Minister’s reference to solar PV is most welcome, and provides an additional

2. T HE B ACKGROUND TO S OLAR P HOTOVOLTAIC

Driven by advances in technology and by increases in manufacturing scale and

18 September 2015 Page 4 of 22

In 2014, worldwide installed PV capacity increased to at least 177 gigawatts (GW),

18 September 2015 Page 5 of 22

3. A VAILABILITY OF S OLAR I RRADIATION IN I RELAND

18 September 2015 Page 6 of 22

18 September 2015 Page 7 of 22

Figure 3.2 Annual amounts of solar irradiation on a horizontal surface, measured in

A presentation by Paul Dykes (SEAI) at a conference held in Johnstown Castle on

18 September 2015 Page 8 of 22

18 September 2015 Page 9 of 22

4. I NCREASING E FFICIENCY AND D ECLINING C OSTS OF

In order to increase the efficiency of solar cells, it is necessary to choose the

According to a recent report by the Fraunhofer Institute11:

18 September 2015 Page 10 of 22

As a result of these significant advances in technology, together with mass

18 September 2015 Page 11 of 22

18 September 2015 Page 12 of 22

Figure 4.3 Wholesale prices of 1.0Wp Chinese manufactured crystalline PV modules,

According to a recent Communication from the European Commission15, a large

18 September 2015 Page 13 of 22

technologies. Regional cooperation where there is common renewable energy

5. P LANNING AND D EVELOPMENT C ONTROL I SSUES

A further advantage of solar PV over other renewable sources of electricity (e.g.,

18 September 2015 Page 14 of 22

Ground-based PV systems do not create the same visual impact as other

6. S OLAR E NERGY I NSTALLATIONS , B IODIVERSITY AND

A number of options exist for enhancing biodiversity on solar farms, including

18 September 2015 Page 15 of 22

In some locations, it may even be possible to undertake restoration of the peatland

7. T HE C ASE FOR F INANCIALLY S UPPORTING S OLAR

18 September 2015 Page 16 of 22

Grants are available to support renewable installations that include solar

18 September 2015 Page 17 of 22

until the Order is approved, or fails to be approved, there is considerable

8. P UBLIC P ERCEPTION , A WARENESS R AISING AND

We have mentioned in section 2 above how German environmentalists succeeded

18 September 2015 Page 18 of 22

• Support solar electricity equally with other renewable technologies with a

9. C ONCLUSIONS AND R ECOMMENDATIONS

PV Efficiency: Solar PV is becoming increasingly more efficient at converting

Risk Reduction: Solar PV is a low-risk and low-maintenance technology which