On Tuesday, 3rd May 2022, Liquid Gas Ireland submitted the below response to the Department of Environment, Climate and Communications to public consultation questions regarding the draft Clean Air Strategy for Ireland.
Do you agree with the five strategic priorities outlined in the draft strategy?
- To ensure continuous improvements in air quality across the country.
- To guarantee the integration of clean air considerations into policy development across Government.
- To increase the evidence-base that will help us to continue to evolve our understanding of the sources of pollution in order to address them more effectively.
- To enhance regulation and improve the effectiveness of our enforcement systems.
- To promote and increase awareness of the importance of clean air.
Liquid Gas Ireland (LGI) welcomes the Department’s five strategic priorities as set out in Ireland’s Draft Clean Air Strategy. In addition, we would like to highlight the role of cleaner, lower carbon and renewable fuels like Liquified Petroleum Gas (LPG) and BioLPG in ensuring improvements in air quality across the country. Both are alternative, reliable, sustainable fuels that produce very low levels of air and particulate pollutant emissions. Furthermore, LPG and BioLPG carry the same low air and particulate pollutant emissions (NOx, SOx and PM), importantly contributing to local air quality.
LGI’s member companies continue to support Ireland in meeting its ambitious climate targets by supplying homes and businesses not connected to the natural gas grid with LPG and BioLPG.
As outlined in our Vision 2040 document, LPG is a clean-burning, smoke-free fuel that cuts carbon emissions by up to 33% compared to heating oil and solid fuels. BioLPG is a chemically indistinct but certified renewable version of LPG, made from sustainably sourced renewable vegetable oils, wastes, and residues, and delivers up to 90% certified carbon emission savings compared to conventional LPG. They play an important role in improving the health of rural communities across Ireland and should be prioritised by the Government in assisting with carbon reduction measures. BioLPG is certified as renewable by the EU and Irish Government and is exempt from carbon tax, meaning it is a great investment for the future.
Furthermore, we wish to highlight that the switch to LPG and BioLPG is cost effective for consumers. Oil boilers can be replaced with an LPG or BioLPG boiler for approximately 3,000 – 5,000 euro in a fraction of the time of electric heat pump installation. Rural households and businesses are at risk of having to shoulder significant up-front costs for an electric heat pump. BioLPG can be used in existing LPG infrastructure and for customers in rural off-grid homes and businesses, this switch is easy and affordable to make, and align with the strategy set out in the consultation to reduce air pollution and promote cleaner ambient air in our society.
LGI welcomes the acknowledgement by DECC that all sources of air pollution arising from the residential sector need to be tackled and that choices made in heating Ireland’s homes can impact on health and that of families, and the communities in which we live.
LGI can support the Government’s low carbon and clean air strategy and net zero ambitions through the supply of LPG and BioLPG. Switching from conventional fossil fuels to cleaner, greener and sustainable fuels like LPG and BioLPG has immediate and lasting impacts on regional air quality in Ireland.
Do you feel there are additional strategic priorities which should be included?
As referenced, alternative energy fuel sources like LPG and BioLPG should continue to be recognised as cleaner, greener and sustainable fuels as part of Government proposals to improve air quality.
Recent figures from the EPA report on Greenhouse Gas Emissions (2021) show that the residential sector accounted for 24% of energy-related CO2 emissions in 2018 in Ireland and was the second largest source of CO2 emissions after transport (which accounted for 40%).
Using LPG and BioLPG, rural communities and businesses across Ireland can contribute to better regional air quality. Renewable Energy Ireland launched its 40by30 report in 2021, which sets out REI’s roadmap to an Ireland where 40 per cent of heat can come from renewables by 2030 and outlines the role that renewable gas (BioLPG) can play. According to CSO and SEAI data, if 500,000 rural homes switched from using oil-fired central heating to BioLPG by 2040, it would save about 1.9 million tonnes of CO2 emissions per year.
The scale of the overall national greenhouse gas emissions reduction targets that have been agreed by the Government mean that significant and timely changes are required over the next few years to reduce the level of carbon emissions from the residential sector — a sector which relies on heavy carbon fuels. Consumers need affordability and choice in order to be able to continue their decarbonisation journey.
The Government must consider what low-carbon heating options are capable of providing immediate, clean, and cost-effective heat and energy without significant retrofit costs. Policy makers need to ensure that as Government starts to move households and businesses away from solid fuels, it does not encourage a switch to carbon intensive fuels such as kerosene, instead it needs to encourage off grid homes to use low carbon heating technologies such as LPG, or risk meeting net zero targets.
How can pollutant emissions data be better used to inform actions at local and national levels?
LGI recommends that more granular reporting of emissions data by the EPA and Local Authorities can give rise to select readings and pinpoint where pollutant data is contributing to poor and dangerous air quality levels.
What do you feel are the most important current and emerging air quality issues in Ireland that require further research?
LGI welcomes the proposal to develop legislation to regulate the broader use of solid fuels in the residential sector and the commitment in the Programme for Government to develop a Clean Air Strategy for Ireland.
19% of Irish homes use solid fuel to heat their homes/water (peat 10%, coal 8% and wood 1%) (source: CSO). Most of these homes are in rural Ireland, with no access to the natural gas network. If peat and coal are to be banned by 2022/2023, these households need a clean and cost similar alternative. Furthermore, most of these homes are not new builds, making an investment in a heat pump solution prohibitively expensive for those households who relied on peat/coal/wood in the past.
Further research by Department of Environment, Climate and Communications (DECC), the Sustainable Energy Authority of Ireland (SEAI) and the EPA on the full use and applications of LPG and BioLPG can assist the Government when developing future air quality policy considerations.
Are there any other comments you have in relation to the draft national Clean Air Strategy?
Liquid Gas Ireland is committed to working with consumers, stakeholders, and policymakers to support Ireland’s goal to tackle air quality, drive decarbonisation and achieve net zero emissions by 2050.
Ireland needs a strong vision for a regional approach to delivering on air quality targets. This must include a clear commitment to cleaner, lower carbon alternatives to solid fuel burning for home heating. Communities off the natural gas grid need support to make the change and LPG and BioLPG can assist in this regard.
LGI look forward to engaging with Government and energy sector stakeholders in the coming weeks and months on the development of Ireland’s Clean Air Strategy and the role that LPG and BioLPG can play.