Introduction

Energia welcomes the opportunity to provide views and input in advance of the finalisation of the PR5 TSO Multi-Year Plans for 2024-28.

Energia has previously provided comments in separate consultations on much of the substance of the TSO’s work programme for the coming five years. This response focuses on only a limited sub-set of the TSO’s plans for 2024-28, in the context of the recent publication of Shaping Our Electricity Future v1.1. In its vision of how the transmission system needs to be developed for the year 2030, there is much crossover between SOEF v1.1 and the Multi-Year Plans.

For the purposes of this response, Energia wishes to submit its views on two particular issues:

Scheduling and Dispatch Programme

Much of how the transmission system is anticipated to evolve to 2030 depends on the successful and timely implementation of the Scheduling and Dispatch programme in its entirety. In the context of the existing physical limitations on the grid, the ability of the system to perform in a more flexible manner is currently frustrated by the lack of technical sophistication of the operating software. Improvements to the scheduling and dispatch software, that would reduce dispatch down without the need for additional new infrastructure, are an absolute priority.

Incorporating storage units into the Scheduling and Dispatch software should likewise be a major priority on the basis of the end benefit to consumers. Storage units, when sufficiently enabled, capture arbitrage opportunities in the market, alleviating peak prices and reducing the quantity of electricity that is dispatched down at times of system stress. Once again, the benefits to consumers would be realised almost immediately and would not require the construction of additional costly infrastructure that will take a number of years to deliver.

More generally, the longer inadequate systems that do not allow all generators to respond to scheduling and dispatch instructions in real-time remain in place, the longer will a myriad of issues impose limitations on a system that must endure SNSP rates of up to 95%. The failure to implement the Scheduling and Dispatch programme in a timely manner would thus have significant implications for renewable running hours.

In the 2024-28 Multi-Year Plan, the Scheduling and Dispatch programme appears under the heading of “Strategic Objectives”, within the “Markets” subsection. The details regarding implementation and plans for progression of the programme are relatively high level. Energia has emphasised the importance of the timely implementation of the Scheduling and Dispatch programme above. Tangible and substantial progress in implementing the programme should form a key part of Eirgrid’s Multi-Year Plans and ultimate scorecard (it is particularly important that the RAs provide a strong oversight role on the delivery of Scheduling and Dispatch).

Energia is concerned that the current rate of progress and forecast timelines are insufficient to match the needs of Ireland’s renewable ambitions. Energia proposes that when the 2024-28 Multi-Year Plan is finalised, detailed and specific objectives regarding the Scheduling and Dispatch form a core part.

Celtic Interconnector

One of the major projects over the time-period of the Multi-Year Plan is the re-establishment of physical coupling with the EU electricity market via the introduction of the Celtic Interconnector at the end of 2026. Much of what is contained within SOEF v1.1 relies on further interconnection between Ireland and other power systems. The Celtic Interconnector is a particular important project in this regard, as well as due to the changes that it will mean for the structure of Ireland’s energy markets.

Work on the Celtic Interconnector is referenced under the “Imperfections and Constraints” heading of the Multi-Year Plan and the subheading of “Interconnection Procedures”. Specifically relating to the Celtic Interconnector, Eirgrid notes the need to work with RTE on a comprehensive multi-year programme to design “how the interconnector will operate in real-time”.

Energia notes that while the Celtic Interconnector project is a welcome and necessary development, it will bring additional risks to the Irish market that Eirgrid will need to proactively manage. Specifically, the increase in the Largest Single Infeed, and the greater potential for significant reverse of flows at short notice due to price arbitrage will have implications for system adequacy, redundancy, reserve, inertia and overall system security. Energia proposes that Eirgird place specific focus on planning for operational security in advance of the Celtic Interconnector, keep market participants well informed of plans in this regard, and make reference to this specifically in the final version of the Multi-Year Plan.

Given the scale of change that industry participants are likely to have to adapt to with the physical recoupling to the EU market, including changes to auction timing and trading platforms, any changes linked to system security need to be communicated as early as possible.

Conclusion

In this short submission, Energia has identified a non-exhaustive list of points for Eirgrid to consider when finalising their Multi Year Plan for 2024-28. Energia would welcome the opportunity to meet with the TSOs on these matters to discuss them further. The issues that we have raised in our submission, and how we propose they are incorporated into the Multi-Year Plan, are consistent with Eirgrid’s duty under SI 445/2000 to operate and ensure a safe, secure, reliable, economical and efficient electricity transmission system.

PR5 TSO Multi-Year Plans 2024-2028 Call for Input Consultation Paper - Submissions

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