Chambers Ireland submission to the Department of Environment, Climate, and Communications on a Microgeneration Support Scheme in Ireland

Chambers Ireland is the state’s largest business representative network. We are an all-island
organisation with a broad geographical reach; our members are the Chambers of commerce in the
cities and towns throughout the country – active in every constituency. Given the importance of local
economies to our members, and member businesses, Chambers Ireland’s perspective is unique
within the Irish business community – we seek to support thriving local economies and recognise the
diversity of business environments that exist across the cities and regions of the country.
Our network uses the Sustainable Development Goals as a framework to identify policy priorities and
communicate our recommendations. We are very supportive of the development of a
Microgeneration Support Scheme in Ireland as it will be an important component in engaging
communities with climate action and supporting us to meet our national climate targets. The proposal
to establish a Microgeneration Support Scheme ties in with our priorities under Climate Action (Goal
13), Sustainable Cities and Communities (Goal 11) and Industry, Innovation and Infrastructure (Goal
9).
Drafted in correspondence with our Chamber Network and associated policy fora, Chambers Ireland
is pleased to have the opportunity to make this submission. It is important to note from the outset that
while we do not have the technical expertise to address a number of the consultation questions, we
nonetheless wish to underline the necessity of an SME and entrepreneur friendly scheme. By designing

the Scheme in such a way that is accessible and SME-friendly, we can ensure that it plays
a positive role in the overall advancement of the national energy and climate targets under the Climate
Action Plan.

Introduction
The growth of the Irish economy in recent years has seen a parallel increase in carbon emissions,
which is at odds with the country’s commitment to the Paris Agreement. The national target is to
have 70% of our energy decarbonised by 2030. This feat is only achievable if we can scale up our
capacity to generate renewable electricity. It is for this reason that Chambers Ireland strongly supports
the escalation of off-shore wind energy, and we have set out our priorities on this issue in a recently
published White Paper on Offshore Wind.

Through this Scheme, Government has an important opportunity to empower and engage citizens,
including the business community, in the generation of their own renewable electricity. This is where
the Microgeneration Support Scheme can be of real value. Chambers Ireland is very supportive of
the proposals to introduce an MSS in Ireland by July of this year and wishes to underline the need to
accelerate the development and widescale establishment of the Scheme as a way of meeting our
climate targets, contributing to energy security, and helping to reduce energy costs for businesses.
We have outlined several points that we believe the Department should take into consideration in
designing and initiating the Scheme. In short, the Scheme should be in line with the approach set out
by the Regulator when it comes to the overall grid strategy and grid connectivity. Secondly, it should
encompass an SME and entrepreneur friendly approach.
Equitable support for businesses
Microgeneration support levels should be set at a level that incentivises the uptake of the technology
where there are gaps in the market (i.e. the revenue received from operating the technology does not
compensate for the cost of that technology). A balance must be reached between providing a
sufficient incentive to cover the difference that exists between the cost of installing a particular
technology and the savings that result from self-consumption. SMEs and entrepreneurs do not have
the same access to resources as larger enterprises. Therefore, expanded subsidies and/or grants
that support the deployment of renewable technologies, beyond those currently available (such as the

Domestic solar PV and Better Energy Communities schemes operated by the SEAI and TAMS II
operated by the Department of Agriculture, Food and the Marine) should be strongly considered to
incentivise uptake and to reduce the burden of any viability gap.

Fair and efficient price for participation
In framing a new MSS, policymakers must ensure that it is equitable and addresses the cost of burden
sharing. The scheme needs to protect business customers and be accessible to all electricity clients.
Thus, the scheme costs must take account of the costs for renewable electricity demonstrated in the
recent RESS-1 auction in order that the sustainable development of Ireland’s renewable energy
resources is achieved.
Establishing the ‘renewables self-consumer’ model for energy generation and consumption in Ireland
and supporting community and citizen participation in the transition to a net-zero carbon economy are
important objectives. We are glad these issues are being factored into the scheme as design criteria.

Reducing administrative burdens
It is important to highlight that while Chambers Ireland welcomes the development of the MSS, it is
critical that any future regulation in this area is flexible and not burdensome on businesses, especially
SMEs. Rigid regulation which has the potential to undermine business participation should be
avoided. It is also important to highlight that any new regulations that may be introduced as part of a
future strategy should not be applied in a way that may harm business competitiveness – especially
for businesses that are adapting, or have adapted, more circular approaches to their operations. The
Microgeneration Support Scheme should be easy for entrepreneurs and SMEs to navigate and
participate in. The scheme should be designed to be SME-friendly and by doing this we can ensure
maximum participation with reduced red tape and administrative burdens.

Investment in Green Jobs, Skills and Training
Addressing the combined challenges of climate change and the post-pandemic recovery are urgent
tasks. If we are to tackle these challenges and kick-start the economy, we must look at the kinds of
jobs we create and ensure that these jobs are available throughout the regions and contribute to
stronger, sustainable domestic supply chains that increase our self-sufficiency and energy security.
An effective MSS presents an opportunity to generate a significant number of jobs to support
renewable installations. When the Scheme is launched it should be paired with a jobs and training
strategy so that skills-needs of the renewable energy sector can be catered for.

Communications strategy and awareness-raising
It has been demonstrated that despite the potential of microgeneration technologies to help Ireland
meet its targets and induce positive shifts in energy consumption, the rate of adoption among
homeowners remains low, at approximately 1.5% of domestic electricity end-users. It is our view that
this can be attributed to a low level of public awareness. Awareness-raising and communication of a
future microgeneration support scheme must be strategic and properly resourced. This should also
include guidance on areas such as building regulations compliance, certification of works, effective
design of the microgenerator, energy efficiently principles and BER assessments.

Concluding Remarks
Matters such as energy security, energy efficiency, climate adaptation and adopting a more ‘circular’
approach to business operations are amongst the issues that are being continuously discussed and
tackled within our Network. It is crucial that the new MSS is designed in such a way that it supports
citizen-engagement and assists Ireland in meeting its 70% renewable electricity target by 2030. Our
objective is to ensure that businesses are prepared for the low-carbon transition, but also to ensure
that national and European policy makers base any decisions concerning targets, investment and
regulation with economic competitiveness in mind.
Lastly, we highlight the opportunity to continue to engage with private sector business representation
and believe this to be instrumental to facilitate fully representative discussions of future pathways and
actions that are informed via ground-up engagement. We emphasis the value of consultations and
welcome all future opportunities to engage on this and associated topics.