The CER and ESB Customer Supply are coming together to offer an export tariff to domestic home owners. So the idea is that if you install a Wind turbine, a Solar PV panel, or a Micro-CHP, you will be in a position to sell electricity to back to the grid for profit. The drawback is that the rate they propose to pay you will be far less than what you currently the pay for electricity. (this is explained by the difference between retail and wholesale prices. Anyway, you can find their proposal here. I’m responding to the consultation and am blogging it here. Sorry for all the acronyms, but hey… thats what google is for…
I am delighted to have this opportunity to comment on your proposal to develop an export tariff for Domestic customers and hope that my comments are helpful and useful. Congratulations to both yourselves and to ESB Customer Supply (ESBCS) on taking this initiative.
My comments on the ESBCS proposal
Financial approach – The proposal set out by ESBCS appears to be a largely based on a simple financial calculation. This does not take into account subtle softer benefits of such generators which tend to encourage their owners to be more aware of energy use, and so reduce consumption, particularly at peak times. This will act to help Ireland Inc. reduce our National GHG emissions and improve security of supply.
Benefits of embedded generation – The proposal does not seem to recognise the benefits of such embedded generation in reducing system losses and generally strengthening the grid.
Need for increased dispatchable capacity on the grid – As identified in Eirgrid’s report on Generation Adequacy report 08, Ireland requires more installed generation plant. This initiative could act to provide some or all of that capacity.
Danger of channelling funding through ESBCS – While I understand the attractiveness of using ESBCS to provide this scheme, doing so is to create a further barrier to other suppliers entering the residential market. Could a system similar to the WPDRS be used to allow all suppliers to provide such a tariff with your support.
Though the proposal suggested that the approximate price comparison between wholesale and retail electricity is two thirds, the price of 9c/kWh is not two thirds of the published domestic kWh tariff, of 16.4c/kWh.
Environmental approach – The proposal does not focus on the environmental benefits of many of the likely technologies to be included in the scheme.
Capacity/Reserve/AER/Wind/REFIT/WPDRS tariff structures – In the past financial structures have been created to facilitate generators which bring benefits to the system which are not simply kWh based. I propose that a similar pragmatic approach be taken here.
Licence to build/generate – Using the current structure, registration of such a large number of generators by yourselves will create great challenges for both the generator owners and yourselves. Is a simpler solution being developed?
The existing Grid Code is not suitable for consumption of domestic generator owners, though the risk their generators will create is potentially greater than all the existing capacity on the grid. Is a more suitable guide/code on the way for their benefit?
Of all the benefits I have mentioned here, greater benefits could be exploited by introducing a similar scheme for small and medium businesses. Could such a scheme be fast-tracked for their benefit.
I believe that the potential scale, environment and security of supply benefits of this scheme are being severely underestimated by this proposal. Furthermore I disagree with asking ESBCS to act as the main agent for the scheme. Provision of funding could be provided by the CER to be paid to any supplier who offers such a tariff. Finally I believe that the administrative burdens this will create are significant, and should not be underestimated.
While I congratulate you greatly on the proposal, I do believe that a larger tariff should be introduced considering the benefits the scheme will bring. A simple net metering structure would provide a far greater incentive and a greater benefit to us all.