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Friends of the Irish Environment’s submission to the Commission for Regulation of Utilities (CRU) consultation on its proposed decision paper for large energy users (i.e., data centres), based on my technical assessment of the impact on greenhouse gas emissions, and Fred Logue’s legal analysis of CRU’s obligations under Section 15 of the Climate Act.

To gain a clearer understanding of the proposed decision paper on the Connection Policy (“Policy”) for Large Energy Users (“LEU”), FIE engaged an independent expert on energy systems and a law firm.This submission offers professional evidenced opinions to assist the Commission for Regulation of Utilities, electricity and gas System Operators, other regulatory authorities, and project developers in identifying their responsibilities and meeting their legal obligations under the Climate Action and Low Carbon Development Act 2015 (as amended). It also aims to support policymakers, civil society, ndustries, and academia in their collective efforts to decarbonize Ireland’s energy system towards developing a more sustainable economy through a regenerative growth model.

Authors

Prof Hannah Daly, Dr Fred Logue

Year
2025
Publication Name
Friends of the Irish Envrionment
Category
Report
Keywords
Data Centres, Policy, Decarbonisation, Ireland, Energy
Link to Publication
https://www.friendsoftheirishenvironment.org/images/Climate/FIE_Submission_to_CRU_202504.pdf

Abstract

The following summarises the key considerations and conclusions from Professor Daly’s 
report:

  • The context and purpose of carbon budgets for decarbonising,
  • Key findings from her report “Data centres in the context of Ireland’s carbon 
    budgets” (commissioned by Friends of the Earth, Ireland) – see Annex II,
  • Electricity-related emissions associated with existing data centre agreements,
  • Demand growth from heat and transport displaces other fossil fuels,
  • Emissions from natural gas connections,
  • Emissions from flexibility options,
  • Carbon leakage arguments.

Energy Policy and Modelling Group

Environmental Research Institute, Ellen Hutchins Building, University College Cork, Lee Road, Cork, Ireland T23 XE10 ,

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