Introduction

Energia welcomes the opportunity to respond to this consultation. Enhanced grid capability and efficiency are needed to be able to transition toward Net Zero. As the grid was developed originally to suit fossil fuel technologies, Energia shares the TSO’s vision that much more development is needed to build a fit-for-purpose low carbon-based system. It is only with sufficient grid buildout, that renewables can be efficiently incorporated rather than contributing to higher levels of curtailment and oversupply.

The Renewable Energy Directive III clearly gives timebound guidelines in which to arrive at a permit-granting decision, of which grid connection is included. While it is yet to be seen how this will be transposed into Irish law, the onus is clearly on the government to facilitate as much renewable generation on the system as possible to meet the Climate Action Plan targets. One of the current barriers to this is that applications which are unsuccessful in attaining a grid connection offer are often left without a rejection decision. A resulting rejection could be used to trigger a range of developer options, including reapplication or the ability to pursue an alternative option such as a private direct line. This would both progress the energy transition at a faster rate by getting more renewables on the system and could end up being less costly for the end consumer. To this end, it would be useful to report on the status of grid offers following the ECP run as well as to begin issuing rejections as a trigger for subsequent developer options.

Are there areas within the Draft Annual Electricity Transmission Performance Report 2022 that you feel require more detailed information?

Energia would welcome additional clarity in relation to why the outturn performance result for delivering new ECP connections in 2022 remains ‘TBC’. Energia’s assumption would have been that ECP offers for 2022 have been both issued and accepted at this stage of the year. Additionally, Table 13 states that 11 offers to new generators were issued in 2022. Does this amount align with ECP, or were these offers given separate to the ECP process?

The ‘TAO Project Delivery Incentive’ and ‘TAO Management of planned outages’ metric performance suggests that all planned works in 2022 were completed. Yet, as discussed further below, the delivery of two Associated Transmission Reinforcements is significantly below the target. This suggests that the outages for these reinforcements are not being included in outage plans, or the TAO Project Delivery balanced scorecard. Table 3 of the Draft Annual Electricity Report shows that the TAO are delivering on the IA milestones, indicating that the issue is during the delivery phase.

Energia would thus suggest that further work is undertaken to uncover ways by which outage durations can be reduced, possibly by benchmarking off previous years for standard work activities, rather than via the current 3-week lookahead procedure. Innovations that allow work to be completed in a more efficient and safe manner should likewise be incentivised.

Draft Annual Electricity Transmission Performance Report 2022 and the Draft Investment Planning and Delivery Report 2022 Consultation - Submissions

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