As biomass is a technology that requires an input so as to produce electricity, sealing a long-term contract for feedstock supply is highly important for the success of the investment. However, this is difficult to be achieved in Ireland, as suppliers are rarely able and reluctant to guarantee a long-term steady feedstock supply. This is despite the fact that Ireland has a strong pastoral sector, but feedstock supply is contingent on factors beyond their control. The problem is more severe, if the feedstock comes from forest residues, due to the fact that the average size of forests in Ireland is very small. If this cannot be achieved, then it is impossible to get the necessary financial support for the realisation of the investment.

The public perception of wind energy in the Republic of Ireland can be considered as a serious barrier. There have been some negative reactions towards prospective RES investments at local level. This is mainly the case for large-scale onshore wind parks. More specifically, anti-wind energy groups along with other so-called “anti-pylon” groups joined forces in order to halt the Grid 25 project, aiming to upgrade the existing transmission system in Ireland and ease the interconnection with Northern Ireland. Even though Irish public opinion towards wind energy is positive, there exists a very strong lobby against wind energy that exploits the “planning wrinkles” so as to stop further development. Even when Ireland transposes EU Directives concerning planning, that lobby looks at every possible provision so as to stop any further construction of wind power projects. That “anti-wind lobby” has also popular and political support in some regions. However, serious steps have already been made to overcome this barrier. More specifically, there have been awareness-raising campaings so as to inform and engage local communities in wind energy deployment.

Irish Wind Energy Association (IWEA) has knowledge about it and tries to tackle it by issuing a Community Engagement Strategy in 2019. One of the most interesting traits due to be published is the introduction of a model of shared ownership as realised in other countries. This Strategy aims to provide guidance from where the Government work ends.

Grid regulation and infrastructure was always considered as a problem for the deployment of wind energy in the Republic of Ireland. The most serious problem is was the duration of grid access that can last in extreme cases up to 20 years. As the grid connection procedure has such a long duration, potential investors apply for a connection to the grid (grid connection license lasted for five years but has been prolonged to ten years) and afterwards for any other planning permit and license (backwards model). This, of course, had a serious effect on the predictability of connection procedure. Apart from that, the wind sector, due to its capacity, followed the GATE 3 process. According to that, if a wind developer had not secured access to GATE 3 until 2007, the Regulator (CER) had no need to offer any connection offer. Looking backwards, there was a more sensible approach with regard to group grid connection. For example, if four plants could be connected to the grid with a common nod and one of them was not finally approved, then the consumer carried the cost so as the rest of them can proceed. However, this provision is removed and now if this situation occurs, the other plants should redesign their grid connection.

Cost of grid connection arise due to the combination of the shallow cost structure, deep cost structure and the grouping of grid connections. The multitude of parameters may create problems in the future. If a shared connection is to be built, then plant operators are obliged to pay for it but the question that arise is who will be the owner of the connection.

One issue that has until now aggravated the situation is the Gate model, where a certain capacity for RES is reserved and there is no continuous and open grid connection procedure. This has created delays in grid access and in cases the planning permit was expired once the wind plant was connect to the grid. However, with the Enduring Connection Procedure (ECP-1), the new grid connection policy, there is less risk on that field. However, ECP-2 will need improvement. Additionally, it is not certain when this new round will take place (first estimation is in May 2020). Consequently, there is a gap of more than one year for new wind power projects waiting to be approved. With regard to offshore wind, a separate procedure should be followed, but the timeline is not known.

The cost of grid access for wind plants can amount to more than € 300,000 per MWh and can even reach up to € 500,000 per MWh. Such a high cost is correlated with other barriers, such as the lengthy duration for grid access. As the duration is long, additional requirements may emerge, thus increasing the aggregated grid access cost. Cost of RES-E grid access is also considered one of the major problems concerning the development of biomass in Ireland. As certain capacities available are already booked up by solar parks, biomass is burdened with an additional (deep) cost of connection.

Lengthy delays for grid connection along with the issues related to the expiration of planning permissions are still apparent, lowering the effectiveness of wind energy projects. Apart from that, a liberal objection policy enables anyone to object to any issue, even though is not directly affected by it. Consequently, there are groups that raise environmental issues and object to the realisation to wind projects, even though they are not located in the area. In some case, these groups are professional and have ample experience in submitting objections for any wind project, while they take advantage of the low-informed local community.

Further planning issues are the ownership of fields adjacent to motorways that belong to the state. However, for any project, those land owners need to be consulted, thus creating additional delays in the realisation of wind projects.

In any case, the processes are very slow. Especially local councils do not meet the deadlines for wind projects below the capacity of 50 MW. If the decision is appealed, one should go to a higher instance, i.e. the Planning Board (An Board Pleanála; ABP). Also in this instance, wind developers are obliged to comply with the deadlines while the ABP is not. Finally, the last instance is to go to the High Court, where the final planning decision will be approved or rejected. This whole process creates unnecessary delays for the realisation of the projects.

This is one of the barriers related to the delay of the Government in implementing the target model for the electricity market. In this regard, the Government fears that the Public Service Obligation (PSO), i.e. the main revenue source for previous and upcoming RES support could not be sufficient to cover the cost of RES support through the capacity mechanism. If not, the PSO should be raised and as this is a levy paid by the customers, the Government is afraid that public opinion will be against that prospective increase. This barrier still persists in May 2019 as it has to be included in the calculation of the support level of the new Renewable Energy Support Scheme (RESS). However, it is expected that no scheme will be introduced until 2020 as the Government has adopted a stop-and-go stance.

There is a considerable delay concerning the introduction of the new support scheme for RES. As of December 2016, it was expected that public consultation would last one year while its revision and the state aid approval from the European Commission might prolong this process to up to two years. The point is that despite the fact that the sector knows what it is going to be introduced, i.e. tenders, the timeline (when and how this will take place) is of great concern. In 2019, the lack of a comprehensive support scheme remains as a barrier. There have been ongoing discussions concerning the introduction of that scheme Renewable Energy Support Scheme (RESS). However, it is expected that no scheme will be introduced until 2020 as the Government has adopted a stop-and-go stance. One of the key issues of that upcoming scheme is its specific traits and, more specifically, if they are technology neutral of technology specific. Several details should be solved. One of the main issues is the standardised approach that foresees community engagement and ownership. The new scheme should clearly define how this can be achieved as it is a prerequisite for taking part in the future tenders. Further issues that should be taken into consideration are contingent upon other barriers such as the treatment of RES dispatch and the unfavourable taxing regime. In any case, this is beneficial for onshore wind energy, which is a competitive RES, but it is not the case for offshore wind energy. So as the 2020 target can be reached, the Government relies on so-called corporate Power Purchase Agreements (PPAs; the first of them was signed recently with Amazon for a 90 MW wind plant). However, this is not considered enough and only big wind plants can profit from those PPAs. In any case, there seems to be a lacklustre ambition up-to-date. The problem is more severe for biomass, as wind energy is regarded as the main RES in the Republic of Ireland, despite its positive effects on the local economy, for example, employment. In addition, in May 2019, it is not certain whether biomass technologies will be eligible to take part in the upcoming tenders.

There are a number of very serious barriers for wind plants that have to do with operating Integrated Single Electricity Market (I-SEM). I-SEM is a new wholesale electricity market arrangement for Ireland and Northern Ireland. The existing market arrangements are replaced by multiple markets or auctions, each spanning different trading time frames, with separate (although related) clearing and settlement mechanisms, covering both energy and non-energy commodities. Principally, the Government chose a market structure option (Option 3) which was ideologically driven, discriminatory against RES and created excessive problems, while it inaugurated in October 2018.

Firstly, day-head market is not a level play for wind energy. This market is mainly designed for fossil fuel plants as there is a commitment for electricity production at least six hours ago. A penalty is imposed on the producers that fail to provide the committed volumes. This is definitely something that wind energy cannot provide and entails many risks. An alternative proposal is to reduce the time margin by five hours.

Secondly, there is the volatility of the balancing market. According to the new provision, the administered scarcity price can amount to up to € 11,000, which is unfair to wind energy, as it is a huge imbalanced market.

Thirdly, the establishment of the intra-day market can be seen as a possible “refuge” for the imbalanced wind energy market. However, the provisions can hinder the participation of wind plants in the electricity market.

Fourthly, there is a pressing issue regarding the amount of support granted to wind energy plants through the capacity mechanism. As the capacity mechanism will be based on a competitive bidding system, wind energy is expected to be considered as a reliability, i.e. can apply to supply electricity in stressed events. In addition, under stressed events (fossil fuel) plants can be remunerated up to 50%. However, during those events wind plants are basically absent (wind generators will hold many if any reliability options, as periods of system stress may not coincide with positive wind output) and thus not remunerated. Consequently, this capacity mechanism excludes wind projects and more specifically new projects. Apart from that, an adjusted support price was expected to be introduced for smaller RES (up to 6 MW of installed capacity in case of wind and 1 MW for other RES) but it was not implemented. Therefore, there is no exception for small RES and this creates an unfavourable investment environment for small-scale and community RES projects.

Finally, the Capacity Remuneration Mechanism is discriminatory and only established fossil fuel plants can profit from it due to high penalties, if the commitments are not met. Therefore, especially small RES are effectively removed from that mechanism.

Curtailment is a long-lasting barrier of the wind sector. Since Ireland has a small transmission and distribution system, curtailment can reach up to 50%. Flexibility should be offered in that field, which is facilitated by the DS3 Programme that will enable more wind electricity exports to neighbouring UK. Although the transmission grid is able to technically operate at the System Non-Synchronous Penetration (SNSP) limit of 65%-75%, this is not regulated until now. It seems that administration should try to keep pace with the impressive technology improvements.

Technically due to the DS3 programme an augmeneted level of RES is feasible.

Taxing regime was crucial barrier due to the fact that commercial property rates have increased and in some case tripled since 2016. The Valuation Office, which is in charge of commercial property rates, initiated a revaluation process that lead to the increase of the rates. Therefore, new wind projects should be revalued and this literally nullifies the decrease of capital costs and the argument that energy costs should be decreased. Characteristically, commercial property rates have increased by up to 200-300% thus creating an additional cost for the development of wind projects. It should be noted that the definition of those rates depend on local jurisdiction and in some cases such as that of the City of Limerick it can rise up to that percent. In any case, the result was that the rate for wind power was doubled, tripled and in some case quadrupled. Logically, this put wind projects under feed-in tariff (FiT) in extreme danger as the increase was introduced after their installation and the beginning of their operation. In contrast, the property rates for fossil fuels decreased by 50%. Irish wind energy stakeholders addressed the issue to the European Commission (EC). Their main argument is that the property tax is a retroactive measure and should be seen as an indirect “state aid” to fossil fuels (i.e. environmentally harmful subsidy). The EC did not act against it and this is why Irish wind energy stakeholders have gone to the European Court of Justice (ECJ) against the EC. It is estimated that this extra bill due to the increase of the property taxes amounts to € 40 million and is still increasing.

Power Purchase Agreements (PPAs) are used generally for biomass, but this is not the case for Anaerobic Digestion (AD) as it is difficult to get through the CHP connection procedure and connect the plant. Furthermore, problems related to digestate by-products might also emerge. For that reason, there have policy delays concerning the issues of by-products list.

Treatment of RES-E dispatch (curtailment) is seen as a barrier for other RES, namely wind energy and/or PV as it is not acknowledged that biomass energy is dispatchable. In contrast with those RES, biomass can provide electricity in a more scheduled manner which is not contingent on the weather conditions, as this is the case for wind and PV. Nevertheless, the advantages of biomass have not been adequately acknowledged and its exploitation potential has not been taken seriously into consideration. In general, there is a lack of acknowledgement of the benefits of biomass as a source of energy and there is no link to the abatement of CO2 emissions. Apart from the production of clean energy, which is CO2 neutral, biomass plants use feedstock as an input for the production of electricity. If unexploited, the feedstock will remain a source of CO2 emissions. However, this double benefit, production of clean energy and use of feedstock that is a CO2 source is not adequately acknowledged.

One of the most crucial problems at that time concerning wind deployment is the delayed process of updating the existing Wind Development Planning Guidelines that were introduced in 2006. The process is ongoing, but it is considerably slow. There is no finalised document so far and this is a major setback, as it hinders the selection and installation of wind energy sites. As long as these are delayed, the more difficult it becomes to accelerate projects that can be realised. Recent developments concern the noise levels and the shadow flickering. In any case, the definition for both issues will have significant impact on onshore wind (+20% cost). Furthermore, there seems to be lack of coordination and integration of local development plans to regional development plants and this also has a severe impact upon development. The Department of Housing, Planning and Local Government stated that a public consultation would have commenced in the first quarter of 2019. However, as this has not commenced yet, wind stakeholders are also unsure.

Primarily, the 2030 target for electricity generated from renewable energy sources (RES-E) for Ireland was set at 55%. However, this target was revised upwards at 70%. Despite this ambitious target, there is still need for a comprehensive strategy so as to how this target will be achieved, as Ireland has not yet prepared a final National Energy and Climate Plan (NECP), although there was a first public consultation on Ireland's NECP in December 2018 - January 2019 (with the 2030 RES-E target at 55%) . The policy tools are more or less known, i.e. Support Scheme RES for electricity and Support Scheme Renewable Heat for the H&C sector. The first step is to immediately introduce both schemes.

There is an urgent need for the detailed design on how offshore wind can reach its route to the market. One of the main issues raised here is the licensing regime. This should be amended so as offshore wind plants can receive consent more easily. To date there has only been 25 MW of offshore capacity deployed, while 3,000 MW are expected in the immediate future. There is a case,however, where offshore wind farms at the east side of the Republic of Ireland have received consent, but are waiting in limbo for their realisation. The simplification and acceleration of the licensing procedure ,especially for those offshore wind farms are crucial for the future of offshore wind in the country. It is certain that some of them will not be realised, but the lessons learnt from that procedure will serve as an input for the future deployment of offshore wind. In any case, the rationalisation of the licensing procedure will prove how offshore wind can be deployed in the future.

This barrier has to do mainly with the necessary expertise need for the new RES support scheme (RESS). This is due to the fact that the sector needs the necessary experts to capitalise on the auctions that will be announced in the future. Furthermore, as the Renewable Heat Support Scheme rolls out, there is an increasing need for companies to educate and train their installers on new technologies in the biomass sector. For that reason, a register of developers and installers has already been established.

Existence & reliability of general RES-H&C (heating and cooling from renewable energy sources) strategy & support scheme is once again the most crucial barrier for the deployment of H&C. A Renewable Heat Incentive (RHI) was included in the Bioenergy Strategy of 2013/2014, drafted by the former Department of Communication,Energy and Natural Resources. Nevertheless, the progress is very slow and deadlines are continuously moving. Under those circumstances, it is really impossible to plan a comprehensive investment. The support scheme for renewable heat (RES-H) was finally launched in 2018 (investment and operational support). the investment support in form of a grant initiated in September 2018. However, the operational support received state aid approval only in April 2019 and has not yet been launched. Therefore, there is a need for the immediate initiation of the operational support. It seems that the scheme should not be administrative heavy, so as investments can be accelerated and not face unsurmountable barriers.

There is an extremely good and modern natural gas network in Ireland, leaving a little level playing field for biomass technologies. Consequently, natural gas is cheaper than biogas and therefore it is not competitive.

District heating networks are very few and small. Therefore, there is a lack of interest in that field.

Injection of biogas into natural gas grid is slowly progressing as there is little “appetite” for biogas.

So as the biomass heating and cooling (H&C) sector can be adequately deployed a reform of the current budget of the scheme is needed. More specifically an increase of the budget is necessary. Characteristically, € 8 million were foreseen in the 2018 Budget.

The excise tax relief on biofuels, applicable until 2011, created positive prospects on the biofuels sector. All in all, eight facilities were operative in Ireland at that time. However, with the introduction of the current quota system, there is a slowdown in the indigenous biofuels market. Only one facility is currently in operation and majority of biofuels are imported. Under the existing quota system, the National Oil Reserves Agency (NORA) issues certificates for each litre of biofuel placed on the market. Generally, one certificate is issued for each litre of biofuel. However, two certificates will be awarded instead of one for biofuels produced from biodegradable waste, residue, non-food cellulosic material, ligno-cellulosic material or algae. However, the price of those certificates is defined at the end of each year or at the beginning of the next year, creating uncertainties on the level of support one plant producer might accrue. Apart from that, biogas market under the current conditions is not open for smaller companies due to the structure of the support scheme. A possible solution can be further financial incentives and further certification for small producers.

Due to the blending limit of 5% that has been defined in Ireland, companies were pushed to import the majority of biofuels pre-blended from the Netherlands or the UK. This leaves little opportunity for Irish producers to produce such blends. The blending has been increased at 11.11% by the Department of Communications, Climate Change and the Environment (DCCAE) and this was welcomed by the sector, while the sector supports the introduction of E10 blend of up to 10% ethanol and 90% unleaded petrol.

Infrastructure is currently missing and needed to be put in place for the further deployment of biofuels. For that reason, funding is needed. Especially, biomethane for transport need to be further supported, as its deployment cost is bigger than that of fossil fuels. However, there is an abundance of feedstock and with the proper policy measures, biomethane production and consumption can be increased.