Introduction:

Bord na Móna (BNM) warmly welcomes this opportunity to provide feedback to the TSO’s PR5 Multi Year Plans 2025-2029 and relative incentives. The Multi Year Plans provide key energy system transition milestones for 2025 – 2029: a period which represents the final years of the national effort to achieve an 80% share of renewables on the energy system by 2030, alongside a 75% reduction in sector emissions. The PR5 period must ultimately progress a system capable of accommodating a net zero society by 2050. With incentive payments retrieved from customer charges, it is essential for both customer representation and energy system delivery that incentive deliverables are sufficiently ambitious. Subsequently, incentive payments must maximise outcomes for customers and efficiently deliver national energy policy objectives.

As a semi-state company, representing consumers’ best interests is at the forefront of BNM’s strategy. BNM is also a leading innovator of climate resilient energy solutions within the Irish energy transition. BNM currently manages over 500MW of onshore generation assets. Meanwhile, our diverse development portfolio includes long-duration storage, renewable gas production, eco-energy park concepts and an offshore development project in joint-venture partnership with Ocean Winds.

We note that the forthcoming PR6 has yet to be finalised and that incentives and workstreams are not a complete reflection of incentive proposals. Our response therefore focuses on the 2024 years within each of the five Multi Year Plans, and we hope it contributes to the delivery of the TSO’s 2025-2029 ambitions, alongside a justified capture of incentive payments.

Response:

1. RES-E Incentives

BNM supports the overall objective of the RES-E incentive to increase the proportion of renewable electricity by 3% each year towards 55% penetration in 2025.

Regarding the ‘Implementation of 2024 Reserves and Ramping measures’ outlined in the Operational Roadmap, BNM recognises the financial challenges associated with accelerating the uptake of renewable generation deployment. However, we believe it is paramount that the viability of existing projects remains stable and intact. Specifically, changes in national reserve should be conscious of existing development investments. Furthermore, future operational models must also ensure that an attractive investment environment remains.

2. Imperfections and Constraints Incentives

BNM broadly supports the approach of the Imperfections and Constraints incentives and welcome the actions outlined in workstream 5 & 6 on imperfections and constraint reporting. In our view, it is important that the costs of constraints and curtailment are reported transparently, as this provides valuable information for the development of the electricity system and future investment decisions. Understanding the operational costs of dispatch down helps in assessing future investments to alleviate them and operate the system at least cost to consumers.

BNM also wholly supports the proposal to reduce and eventually remove the minimum conventional unit constraint, as a measure that simultaneously increases the uptake of wind energy in the system and reduces the sector’s emission intensity.

3. Investment, Planning and Delivery

BNM note that the current Investment, Plannig and Delivery incentive metrics are reflective of Ireland’s Natoinal Development Plan. BNM supports the approach of allocating weighting to the delivery of metrics and appreciate the value of stakeholder engagement in investment and planning.

In the interests of accelerating energy infrastrucutre and maximising value for consumers, we do however believe a significant proportion of the incentive payument should be linked to actual delivery of infrastructure. Specifically, weighting of investment planning should be reduced to place a higher importnace on delivery, rather than simply fulfilling the steps involved in the process.

4. Strategic Objectives

BNM wholly agree with the TSO approach of combining Network, Market and Operations activities as a balanced means of addressing the key strategic incentives. Regarding the 2024 milestones encompassed within the Networks activities, BNM supports ‘increasing efficiency for customers and anticipation of future investments’ as an essential incentive, for the merit in which anticipatory grid investment holds for resolving system-wide grid constraint.

Regarding the 2024 milestones under Operational activities, BNM note that at the time of writing, the ‘implementation hybrid technology connection’ plan as well as a completed study on ‘the decision to commence 80% System Non-Synchronous Penetration trial’, have yet to be delivered. It is therefore our view that these milestones should not be included as deliverables for receiving incentive payments.

5. Local Security of Supply

BNM notes that the TSO incentive plan regarding security of supply aligns with the CRU’s strategic aim to address the issue of energy constraints in the surrounding Dublin area and will contribute to their removal. BNM also believe however, that in order to reflect national policy visions, the Multi Year Plan should also consider incentives to redirect future demand away from Dublin, to areas where the grid is less constrained. The CRU’s National Energy Demand Strategy[1] specifically calls for the relocation of demand centres, as well as the co-location of renewable energy generation.

Furthermore, in the interests of security of supply, BNM believe an additional incentive should be included on the introduction of a national policy objective on the delivery of new gas fired generation by 2030. To abide by carbon intensity requirements, the energy system requires at least one CCGT[2]. It is vital that this is accounted for in the forthcoming and future capacity auctions.

[1] CRU, 2024, https://www.cru.ie/about-us/news/cru-national-energy-demand-strategy/

[2] EY, 2022, SEM-22-054A Performance of the SEM CRM.pdf (semcommittee.com)

PR5 TSO Multi-Year Plans 2025-2029 Call for Input Consultation Paper - Submissions

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