GRANT ENGINEERING IRELAND ULC
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GRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
Draft NECP 2021-2030 Consultation,
Strategic Energy Policy Division,
Department of Communications,
Climate Action & Environment,
29-31 Adelaide Road,
Dublin 2,
21st 2 February 2019
Re: Draft Consultation - NATIONAL ENERGY & CLIMATE PLAN 2021-2030
Grant is Irelands largest indigenous manufacturer of home heating appliances, it is
headquartered in Birr (Population 5600), County Offaly where it employs 360 people
and a further 82 people in its International subsidiaries. We are members of
OFTEC and the HPAI. Grant manufactures and supplies in to the Irish market
renewable heating appliances i.e. Air Source Heatpumps , Solar Thermal Panels and
Wood Pellet Boilers. Grant also supplies liquid fuel boilers (for both Kerosene and
gas oil). Grant has 54% of the UK liquid fuel residential boiler market (Source EUA
2016) There are no independent statistics for the Irish market but, having been in
business for over 40 years, and based on our historic sales figures, we believe that
our appliances heat up to 400,000 of the 680,000 plus houses that use liquid fuel
in Ireland.
As Kerosene and Aviation fuel are distilled in the same process there has, to our
knowledge, been no impact studies on any changes to existing kerosene supply
such as bio-blending/ reduction of supply, increased carbon tax, storage and
blending issues, distillation issues and price impact etc. Also, no studies on the
impact to industrial users for this distillate used in non-heating/transport purposes.
Rural Ireland is highly dependent on liquid fuel for home heating, according to the
CSO a national average of 40% and up to 76% in County Monaghan. This is
because it is the most affordable method of heating a home in rural Ireland that
delivers the required comfort. Given that liquid fuel dependence is only 11% in
Dublin, any increase in home heating costs in Rural Ireland will be perceived by the
electorate as discriminatory, unfair and another disadvantage and cost burden of
living in Rural Ireland. If carbon tax is used as an instrument to move households
to less carbon intensive heating it should be done over a long period of time in
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAY
GRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
very small increments. It is vital to manage the transition to a lower carbon future
by putting fairness at the core, otherwise government policy risks alienating the
electorate in Rural Ireland. For example, being based in the Midlands we have seen
private commercial turf cutting end and energy production using peat end this has
and will result in large job losses in this area. Resulting in economic decline and
further Rural depopulation in this area, but to date we have seen little in policy,
planning and strategy to alleviate this. Bearing in mind also that the recent TASC
report states that 24% of the Irish population is at risk of falling into poverty, in
Rural Ireland fuel poverty is a major contributor to poverty.
As a company that also sells Air Source Heatpumps and believe they are a good
technology and have an important part to play in decarbonising residential heat, we
would have several observations to make.
Air Source Heat pumps are an appropriate heat source for New Build houses, driven
by part L of the building regulations and the required level of air tightness in the
new building, as a result of changes to DEAP software methodology Air Source
Heatpumps are becoming more popular in new residential homes.
They are very expensive (for example our liquid fuel boiler at retail will cost on
average €1500 while on average a heat pump will retail at €4000. If you install an
Air Source Heatpump then normally, either underfloor heating or radiators that are
suitable for Air Source Heatpumps must be used, this becomes a very expensive
heating system to install compared to your traditional steel panelled radiators that
are used with a liquid fuel boiler. So, in a new build with a high level of insulation
and airtightness, a medium temperature heating appliance such as an air source
heat pump will heat the house comfortably.
Retrofit however is a very different matter. Any home above a C1 has a possibility
to be suitable for a heat pump as they can be brought up to a BER A rated house,
which we believe, is the type of standard a home needs to be to allow a medium
temperature appliance such as a heat pump provide heating comfort without
excessive electricity bills. This will though require substantial investment by the
householder.
The issue that the householder faces is the cost versus benefit. To put this into
perspective according to Sutherland, January 2019 data, for an average 3 bedroom
house in Ireland the current cost of heating your home with a Condensing LPG
boiler and radiators is €2574, an Air Source Heatpump and radiators is €1852, a
Condensing liquid fuel boiler and radiators is €1606 per year, Air Source heat pump
and underfloor is €1458. So, for a householder to invest a huge amount of money
into switching from an existing condensing liquid fuel boiler to an Air Source
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYGRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
Heatpump with the additional cost of underfloor heating to save approximately €150
on their heating bills, makes it a very difficult choice.
Also considering as the airtightness or BER rating increases so to does the heat
load so the cost of heating the property drops proportionately, like for like.
Bearing in mind that 90% of our homes are below a C1, to upgrade from a D
rated house to an A1 rated house will cost in excess of €50,000, depending on the
scale of measures that are required. Not to mind the disruption of having wet
tradesman ie plumbers, plasterers and painters in the house during retrofit.
Given that both a liquid fuel oil boiler and an Air Source Heatpump has a life span
of approximately 10 – 15 years, this amortisation for the householder needs to be
considered.
The other issue is that given the small population of Air Source Heatpumps in rural
areas currently and given the distances service engineers will have to travel in the
event of a breakdown, the householder will not get the same service. This is a
result of two issues, over the last 30 years of liquid fuel heating in rural Ireland a
large network of service engineers has developed - in excess of 1500, in
comparison there are no more than 300 Air Source Heatpump service engineers
(mainly based in urban areas (i.e where the majority of housebuilding is currently
happening). Has there been a study on the economic impact to excise revenue, job
losses in fuel depots, service engineers, fuel delivery drivers, and closure of fuel
stores and delivery depots?
There is also a substantial increase in costs to servicing an Air Source Heatpump
and there are several critical parts, that if they fail, will result in the uneconomic
repair of the Air Source Heatpump. The reason for the higher service costs is down
to the qualifications required to service Air Source Heatpumps such as Fgas
qualified and electrical qualifications. Where a liquid fuel boiler service engineer
does not require this level of qualifications. Also, baring a leaking shell, the most
expensive replacement part of a boiler, is the burner, which can be replaced for
less than €300.
The other issue is boiler breakdown, this normally occurs during winter, it becomes
a distressed purchase, as no one wants to be without heat during this time. So, the
idea of having to wait for multiple measures such as cavity wall insulation, triple
glazing, heat loss calculations, is not going to happen.
In a retrofit, moving from a condensing liquid fuel boiler (high temperature 75
degrees) to an Air Source Heatpump (medium temperature 55 degrees) is
complicated, expensive, disruptive, and really is only applicable to those that can
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYGRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
afford it and are upgrading their house such as expanding family, do not want to
move location etc. In conclusion Air Source Heatpumps are not a panacea to
moving to low carbon residential heating in rural Ireland (Retrofit)
The German Experience with Liquid fuel Heating
The above graph is interesting it shows the number of households in Germany
heated by oil (orange line) from 1996 to 2015 it went from 5.9 million houses to
5.5 million houses, less than a 7% drop, a large number connecting on to mains
natural gas grid.
The interesting part of this was the level of oil consumption dropped 58% while the
consumption per meter squared dropped 45%.
This was done with a combination of government financial supported measures,
done incrementally over time.
Non-Condensing liquid fuel oil boilers were replaced with High efficiency Condensing
liquid fuel boilers this equated to an approximated 20% drop in fuel consumption
and hence Carbon emissions. This process began over a period of 10 years from
the late 90’s early 2000’s.
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYGRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
This was improved with the combined financial assistance for adding heating system
controls (a further fuel reduction of approximately 5%). It then combined supports
to install a wood stove (sealing chimneys increasing air tightness, a chimney results
in up to 40% heat loss in a room) and or solar panels (thermal).
20% of home heating requirements is Direct Hot Water (DHW) so solar panels will
effectively provide DHW for up to six months of the year thus reducing fuel
consumption by a minimum of 8%. One consideration regarding Solar thermal
panels, in most of Europe Solar panels are the preferred option as opposed to
tube. Solar panels have a life span of 30 years plus and require minimum
maintenance. Tubes on the other hand, while an easier install, have a shorter life
span due to the fact that they operate in a vacuum and over time this vacuum
depletes and rubber seals breakdown, so there is a higher maintenance
cost/shorter life.
The other point, is that any financial support for Solar Thermal should not be on
the square meter of the house, as it is currently to avail of current support, it
becomes very expensive resulting in the payback for the householder being too
long. The most affordable system is a two panel on roof system which fitted, will
cost the householder approximately. €3500 to €4000. Given that the annual cost of
Direct Hot water is approximately €200 this is a 20-year payback. If a subsidy of
50% was paid, then this is a 10 year pay back. Given that the panels have a
longevity of 30 year plus it becomes attractive.
Through out the above timeline, insulation and increasing airtightness measures
where heavily promoted in Germany and subsidised. This also has the effect of
reducing the required heat load of the house and a reduction in fuel consumption.
All the above was done here in Ireland, but the level of financial support, scale of
uptake, level of bureaucracy, all acted as a barrier. To the point, where there are
no independent statistics available, but industry would say circa 50% of the current
liquid fuelled homes (circa 350,000 homes) are still using non condensing liquid fuel
boilers and that the average house is only a BER rating of E/D. Nowhere near the
results achieved in Germany.
Before moving on to developing another strategy, consideration should be given to
the German Model and reapplying it to achieve similar results to what has been
achieved in Germany.
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYGRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
The Future
If Ireland had achieved similar results to Germany, then a much larger number of
homes would be in a position to consider a heat pump it would have also reduced
carbon emissions substantially.
Going forward Hybrid Heating solutions will play a critical role in low carbon
residential heating. We have seen how Solar thermal can play an important role in
Direct Hot Water. Heat Pumps combined with existing condensing liquid fuel boilers
will allow householders to reduce carbon emissions dramatically due to reduced
fuel consumption.
By integrating these two appliances, the Heat pump will become the primary heat
source however it will only provide heat when economically viable to do so which
effectively means eight to nine months of the year (medium heat demand).
The existing oil boiler will only cut in when the Air Source Heatpump cannot meet
the householders demand for high temperature heat economically, that is when
SCOP begins falling towards 1 (pure electrical heating). This obviously happens in
very cold weather. But it means that the householder does not have to change the
heating system (radiators) it can work at current levels of insulation allowing the
house holder to improve this over time. In the event of a break down one of the
two appliances will continue heating allowing the householder to look at their
options without distress.
This technology is currently available, we have various models already placed in the
market.
Bio-Blending of kerosene is also a future pathway that can be combined with above.
All of our appliances are suitable for a bio-blend of up to 30%. Germany is moving
towards a 10% blend. There are however very specific issues to Ireland with this, it
is not our area of expertise. Europe uses gas oil so their blends can be aligned
with general transport seamlessly. Ireland however uses Kerosene which is distilled
with Aviation fuel. How much consideration was given to this when RES-H targets
were set. There needs to be an impact study carried out to see how any changes
to RES-H policy will impact aviation fuel and in particular around Bio blending.
The use of Rapeseed in bio-blending may also have the benefit of reducing
methane if substituted for Cattle rearing, if feasible and economically viable.
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYGRANT ENGINEERING IRELAND ULC
CRINKLE, BIRR, R42 D788, CO. Offaly, IRELAND
Telephone: (057) 9120089 Fax: (057) 9121060
Email: info@grantengineering.ie
Website: www.grantengineering.ie
Having considered the above, we find the proposal to arbitrarily move 170,000
home from liquid fuel to Air Source Heatpumps as aspirational but lacks practicality
for all the reasons above.
Given the unique situation of Rural homes and the potential bio-blending of
kerosene/aviation fuel, I refer to a recent article in the Renewable Energy
Magazine where Paul Deane of UCC quoted “ a 2% blending obligation of
renewable gas from 2021 would give a similar contribution to converting 170,000
homes from oil to Air Source Air Source Heatpumps in terms of emission reduction
and compliment the policy to make heat cleaner.”
The proposed electrification of Transport and the proposed electrification of Heat
will require billions of investments in the National Grid. Peak energy demand
coincides with peak home heating demand. There is also the dilemma of the fuel
source of this electrification, when we look at Moneypoint (Coal Burning) the idea of
moving highly efficient liquid fuel boilers with efficiencies of 90% to a coal burning
energy generating station with a fraction of this efficiency. To move current fossil
fuel burning energy power stations to renewable energy will also cost billions. While
wind has made a huge impact to our national renewable energy contribution it is
unpredictable* (need for a mixed fuel energy model) and this will require billions of
investments in battery storage if electricity is to be available when wind is not
blowing.
The cost of all the above will ultimately find its way back to tax payers (higher
taxes) householders (higher energy, heating and transport bills) particularly a higher
burden on rural householders due to lack of public transport etc and to Industry
(higher energy and production costs and transport costs) resulting in higher costs
and uncompetitiveness
Therefore, the decarbonisation agenda should be gradual, fair, balanced with no
one sector of society bearing the brunt.
*http://www.dailymail.co.uk/sciencetech/article-5812811/Wind-turbines-standstill-wind-
disappears-thew-UK.html
Registered Office: Crinkle, Birr, R42 D788, Co. Offaly, Ireland
Registered Number: 143329
DIRECTORS STEPHEN GRANT, MAURA GRANT, NIALL FAYYou can also read
