The Electricity Association of Ireland (EAI) welcomes the chance to respond to this EirGrid and SONI consultation on DASSA Product Review and Locational Methodology. The EAI is the representative body for the electricity industry and gas retail sector operating within the Single Electricity Market (SEM) on the Island of Ireland. Our membership comprises utilities that represent the generation, distribution, and retail business activities within the market.

Below is a summary of the main comments with the DASSA Product Review and Locational Methodology Consultation Paper, with more detail provided in the following sections:

The lack of interaction between different DASSA consultations
The introduction of uncertainty to DASSA products via a potential additional Frequency Regulation Product with very little commentary provided.
A lack of detail on proposed changes to system service product definition (FFR 2 second requirement reduced to 1 second)
No consultation on the bundling of products despite being deferred from the DASSA design consultation paper.
Limited engagement with EAI on concerns with the treatment of scalars despite industry responses to the DASSA design consultation
Lack of consultation on the Locational Methodology as the paper only states the locations to be applied in the DASSA.
Clearer documentation on the EU compliance of the DASSA proposals would be appreciated.

Interdependency Between DASSA Consultations

This consultation paper reviews the products and the locational methodology for the reserve services that will be included in the Day-Ahead System Services Auction (DASSA). However, the design for the DASSA market has been consulted on in advance of this paper on the products to be procured. The paper includes no analysis of how any of the proposed changes to the product specifications or additional products that might be included will actually be procured through the DASSA market. For example, how the downward products being translated in negative volumes in the DASSA auction would be remunerated.

There is a disconnect between the two consultations, leading to a lack of certainty for industry of how changing a variable in one consultation affects the output from the other. EAI members feel that a product review (and a signal of even indicative volumes of products) for the DASSA market should have been done in advance of a consultation on the design of the market. The modifications or changes that are made to system services products as a result of this consultation will have a significant impact on how market participants evaluate the appropriateness of the design of the market, both for existing and for new providers.

An example of this is the introduction of ‘downward’ reserve products to mirror the existing ‘upward’ products will add complexity and the examples provided for the DASSA consultation did not include any examples with negative volumes. Whilst industry is broadly supportive of downward products being included and understand the necessity of these services, how they are expected to be offered and remunerated is quite critical. Particularly, where there is this focus on continuous provision, which might not even be in the same direction.

The proposal to procure RRS and RRD together given that these services are distinctly different is of concern to industry. It would also be neither logical nor fair to apply the same availability or event scalars across both products. The proposal could significantly adversely affect peakers and would not be technology agnostic. Lastly, the disconnect that is extremely significant is the interaction of these new requirements with Grid Code parameters, as well as the impact to existing units where the units have already been commissioned within existing service parameters.

Additional Frequency Regulation Product

The consultation alludes to a new frequency regulation product that could be procured in the future to provide dynamic frequency regulation. The TSOs believe such a product would require further analysis and investigation. We would suggest that this needs direct engagement with OEMs to ensure that these services are possible. We would also expect far more evidence to be published by the TSOs to support this investigation. As this is the product review that will deal with reserve products to be procured in DASSA, industry participants are unsure where in the Phased Implementation Roadmap this would take place. The next scheduled product review consultation in Q4 2025 will focus on non-reserve products and the EAI would expect that this review takes a far more holistic approach and explores what are the future system service products that can provide system security into 2030s.

Fast Frequency Response (FFR) Activation Time Modification

The reduction of the standard Fast Activation Time (FAT) of FFR from 2 seconds to 1 second may have significant impacts on multiple technologies including wind assets and CCGTs as many of these assets have 2 second activation times. Omission of an impact analysis from this proposal is a serious gap as such a change would effectively mean that most wind assets and CCGTs would be providing FFR with zero remuneration. This would not be right nor fair and would run counter to reasonable objectives which we believe should be encompassed within the DASSA code, yet to be developed.

This is a conflicting proposal as it is unclear both in terms of volumes that are expected at each of the activation sub-categories, as well as the commercial value of these new services compared to the degree of investment for either new projects or refurbishment of existing units to meet these new parameters. It is also a situation where there is limited evidence provided by the TSO to support this move and to support their expectation that this change is in fact feasible for existing as well as new service providers. This is especially relevant when considering Grid Code parameters which have predetermined certain technical factors that will also be impacted by this faster activation time.

The change is positive for battery assets which is welcomed but as above, the commercial value is entirely unclear, and a full impact analysis on the loss to thermal and renewable assets is required. Since system service revenues support units in addition to power market trading and support scheme contracts, this revenue needs to be earned elsewhere to allow units to remain feasible. The approach to providing these system services must be as technology agnostic as possible. Furthermore, the change in the activation time and the additional reference to quality of FFR services, require direct engagement with OEMs as many of these parameters are regulated by station governors, and how these changes will be incentivised and instructed must be clarified.

Bundling of Reserve Products

The bundling of reserve products as described in the consultation could have significant impacts for the design of the DASSA market. It is unclear the value and utility of bundling of services and how this compares to the concept of continuous provision. It was EAI’s understanding from the DASSA design consultation paper that greater consultation on the “bundling” of products would be held in this DASSA Product consultation. Unfortunately, the level of consultation is not at the level expected with only two sentences on the subject. Therefore, EAI believes a consultation on the application of bundle, quality and continuous provision is needed before any decisions can be made.

The EAI is supportive of the review of the products needed and requirement to ensure that the system is secure and resilient to any frequency events. However, all proposed approaches must be technology neutral and not unduly favour some technologies over others. Impact analyses must be undertaken to ensure all modifications to system service product specifications do not have unintended consequences. A diverse portfolio must be brought forward and not be skewed towards one technology. The battery fleet is not fully optimised yet especially around manual schedule and dispatch commands. If batteries are in charge and providing downward reserve product, will this be clear to the system operator?

Scalars

Scalars are difficult to comment on as the information provided to this point has been quite vague. This consultation points to the DASSA design consultation for clarity, but the DASSA consultation indicates that further consultations will provide more information. This again indicates a disconnect between the development of the consultations.

It has been made clear by the SEM Committee that the DASSA is expected for services that are deemed competitive, and that was the rationale for reserve products to be targeted as the first products to be procured through this auction. The definition of a competitive market is that there is no need for regulatory intervention any longer (e.g. restrictive auction price caps, a BCOP, and scalars as proposed in the DASSA design consultation). Scalars are a feature of the existing Regulated Arrangements and therefore are inappropriate where competition exists. If the TSO is concerned about lack of participation or delivery—these are a function of the design of the market (to make it a suitable market for providers, not only the procurer) and are a function of the dispatch approach to system services. Depending on the DASSA design decision (including the proposed auction price cap and BCOP), a market without scalars needs to facilitate price formation that reflects scarcity. Therefore, as per our comments above, there is a clear need to ensure there is clear linkage between the decision-making process of the DASSA design consultation and the DASSA product consultation.

As per the information we have to date (no decision on the DASSA design consultation), scalars may not be appropriate for the DASSA design as:

The Availability Performance Scalar appears to be a double counting of the Compensation Payment and EAI do not accept that 2 penalties are required.
Scalars already exist for the provision of generation, which units must seek to ensure is remunerated first in DAM, before being able to provide system services. Additional scalars will have a compounding effect as a secondary service to generation, and furthermore, may act as a stronger deterrent for participation in DASSA.

The EAI has been consistent in our messaging that scalars are not appropriate where other market intervention are absent (e.g. where there are no auction price caps and where BCOP in DASSA is not entertained)., Why the TSOs have refused to address these points on scalars is not clear and has never been answered.

Locational Methodology

Unfortunately, no methodology for determining the locational constraints in the DASSA design has been presented in the consultation paper. Considering the significance of constraint in the DASSA design, it was expected that the TSOs would consult upon the methodology for determining how a constraint is introduced and removed from the DASSA. EAI request that an appropriate consultation be provided on the locational methodology that will be applied to all of the frameworks within the Future Arrangements of System Services i.e. Fixed Term Contract, Layered Procurement Framework and DASSA.

EU Compliance

There is still considerable uncertainty around the compliance of these products when EU reintegration occurs in 2026. The Electricity Balancing Guidelines poses a large-scale impact on the operation of the SEM and on system services particularly. We have heard on several occasions that DASSA design is compliant with EBGL. However, the SEMC have yet to make a definitive decision on EBGL implementation in Ireland and to include system services in this scope. The last consultation on EBGL purposefully excluded system services as being out of scope and there has been no change in this interpretation by the competent authority.

Specifically, the definition of standard versus non-standard system services products between SEM and EU are not clear and is particularly relevant in this paper when considering changes to products, provision of additional sub-categories, as well as inclusion of upward and downward products. It is unclear whether these products as currently defined would also be consistent with those in MARI and TERRE in 2026 or if this product review has been not considered a future proof approach not only to consider the evolution of services, but evolution of trading across the EU zone following the energisation of the Celtic interconnector.

SOEF Markets – Future Arrangements for System Services – DASSA Product Review & Locational Methodology Consultation Paper - Submissions

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