Submission to the Public Consultation on the Design and Implementation of a Renewable Heat Incentive

The Renewable Heat Incentive (RHI) subsidy aims to make savings against penalties likely to be incurred by
Ireland for not meeting the EU 20% Renewables­ by­ 2020 obligation. However, the Consultation Document
fails to show that it will in fact save public money. An RHI would commit the State to long­-term funding of
a biofuel heat sector despite there likely only being a couple of years to make savings against compliance
costs. There are financial, administrative, air pollution and climate reasons to avoid expansion of domestic
biofuel production and combustion. This Document fails to make a substantive, quantified or costed case to
address these problems. Due diligence in the Department of Finance, DPER and in public consultation
requires a far more finalised proposal to be made available for comment once more costing and academic
assessment is done.

An Taisce favour charging a carbon pollution fee on all carbon dioxide emissions, including those from
burning biomass at the same rate as the current carbon tax on fossil fuels. This revenue raised can then be
used to fund the retrofit measures in both the ETS and Non­-ETS sectors that will reduce both heat demand
and emissions. If they meet strict sustainability criteria, showing real emission reductions, biomass and
biogas production could be funded on a feed­-in tariff basis like other renewables such as solar where a
subsidy makes sense.

Read the Full Submission below