Hydrostor believes the current award criteria framework is not well aligned with the strategic objectives of procuring true LDES technologies. The proposed criteria appear to favor short-duration battery technologies and hybrid configurations, which may address local dispatch-down issues but do not reflect the broader system value that LDES technologies like Hydrostor’s A-CAES can deliver. We would suggest this award criteria should not be an enduring element of the scheme design.

Before designing an enduring procurement assessment process, it is essential to quantify the system need (Action 7). Without a clear understanding of Ireland’s flexibility requirements—both in terms of duration and volume—award criteria risks being misaligned with long-term objectives. The UK’s Clean Energy Plan 2030 and NSW’s Electricity Infrastructure Investment Act both started with system need identification before designing procurement frameworks. This approach ensures that evaluation metrics reflect strategic priorities such as adequacy, resilience, and decarbonisation—not just short-term curtailment relief.

Hydrostor has the following concerns with regards to the current weighting:

Overemphasis on Cost – A 50% weighting risks prioritising lowest upfront cost over long-term system value, which is counterproductive for infrastructure-scale LDES assets with 50+ year lifespans.
Connection Method Bias – Heavy weighting for hybrid/co-located projects could exclude standalone LDES assets strategically sited for system adequacy and resilience.
Location-Based Scoring – While curtailment mitigation is important, it should not overshadow contributions to inter-day flexibility, resource adequacy, and decarbonisation.

Hydrostor would like to draw EirGrid’s attention to some examples of International best practice with regards to LDES project assessment:

UK LDES Cap & Floor (Ofgem & NESO) uses a multi-criteria assessment that evaluates:
- o System value (flexibility, adequacy, decarbonisation impact).
- o Technology neutrality.
- o Cost-benefit analysis (consumer impact vs system contribution).
- o Deliverability and financial robustness—without rigid weightings.

NSW LTESA Framework applies a two-stage process:
- o Stage 1: Social license, deliverability, organisational capability.
- o Stage 2: Quantitative cost-benefit assessment, considering system benefits (generation shape, curtailment avoidance) and scheme costs.

Both frameworks prioritise net system value and consumer welfare over short-term costs, ensuring strategic assets are selected for their long-term contribution.

Hydrostor would suggest the best course of action to develop an enduring project assessment framework would be to:

Complete Action 7 quantification of need before finalising enduring award criteria.
Replace rigid weightings with a multi-criteria approach that evaluates:
- o System-wide flexibility and adequacy.
- o Contribution to decarbonisation and resilience.
- o Deliverability and financial robustness.
- o Incorporate technology-neutral scoring and lifecycle value metrics.

In summary, under an enduring LDES procurement framework award criterion should be grounded in a quantified system need and a holistic, system-value-based approach should be adopted, drawing on lessons from the UK Cap & Floor and NSW LTESA frameworks. This will ensure Ireland’s procurement process delivers enduring flexibility, resilience, and consumer benefit.

Long Duration Energy Storage (LDES) Procurement Mechanism Consultation - Submissions

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