In general, BGE supports the concept of procuring LCIS given that it will overall contribute to the achievement of decarbonisation targets. LCIS should also ultimately deliver benefits for consumers in terms of facilitating lower cost generation and an efficient electricity system. Our main consideration however is about the electricity system and its efficiency.

The consultation[1] has defined, on the back of studies undertaken by EirGrid, three “incentivised” zones where LCIS is considered as having the potential to bring most benefits. The zones are in the North, the North-West, and South-East. Our understanding is that infrastructure works, and improvements will be concentrated in these three areas to facilitate the develop of LCIS in the next few years. What is unclear to us is whether, or to what extent, consideration has been given to how accommodating the LCIS units will impact on existing constraints in the remainder of the island. BGE has continued long-standing concerns about the lack of transparency around how the current bottlenecks and constraints on the grid will be fixed or mitigated prior to 2030.[2] While a number of EirGrid documents exist around network plans and projects that are in EirGrid’s 6-step process, none of them in our view coherently provide a picture of which constraints are considered the most troublesome (primarily from a ‘cost to the consumer’ e.g. imperfections charge, perspective), or which constraints are being prioritised by EirGrid in terms of being addressed through reinforcement or market-based solutions for example. This is despite several TSO performance incentives that centre on improving constraints and reducing consumer costs. Similarly, it is not clear what the impact of the infrastructure changes, that may be needed to accommodate the LCIS units that materialise on foot of this competitive process, on existing constraints will be. Will the required infrastructure for the “incentivised zones” for example aggravate existing constraints, or will the grid changes that result from LCIS procurement simultaneously improve or at least mitigate existing constraint issues?

BGE has relayed its concerns via a number of channels, in response to consultations primarily, regarding the opaqueness around for example constraint impacts of the connection of the Greenlink and Celtic interconnectors and what the network and/ or market-based solutions are that will be taken to address constraint implications. The same concern now arises on foot of the connection of new LCIS units. We ask that the infrastructure changes decided upon to accommodate new LCIS units, will simultaneously work to improve or at least mitigate existing grid bottlenecks and we would welcome confirmation that transparency on an approach that will be taken to ensure this outcome will be provided soon.

In summary we are supportive of the proposed procurement of LCIS units but akin to our grid concerns around connecting Greenlink and Celtic interconnectors and indeed new offshore wind in future, it is critical for transparency to exist around how the impacts of the connections of all these new types of units will either aggravate or mitigate existing constraint issues on the Irish network. It is not sufficient to adopt a piecemeal approach to addressing grid constraint problems or for the approaches taken to address existing constraints and mitigate potential constraints to be non-transparent. The sooner constraints are reduced or ideally eliminated via grid or technology or market-based solutions the sooner competition can occur on a more level playing field across market participants. A more level playing field in competition in the market will overall lead to reduced costs for consumers.

[1] Question 2 refers

[2] We note that the Shaping Our Electricity Future work focuses on the year 2030 and not interim plans

Consultation on Low Carbon Inertia Service (LCIS) Competitive Procurement - Submissions

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