1. High level objectives of the plan: in order to meet climate targets, "economic growth" should not be a target in itself. Instead, objectives should focus on supporting well-being through reliable and equitable access to energy for essential needs, and facilitating sustainable and circular economic activity. The parts of the plan about "protection settings for largest customer" - it is not clear why the focus should be on protection of large customers rather than small customers and households.

2. "Whole of system" approach and emissions loopholes: It is good that a "whole of system" approach is called for, this should involve addressing loopholes whereby demand side fossil fuel generation which does not meet Eirgrid's environmental and emissions criteria for demand response participation is getting around those rules by instead participating in ESB's beat the peak programme where the same standards do not apply. Demand response incentives by both Eirgrid and by ESB networks should facilitate genuine load-shed demand response, and energy storage, and not use of fossil fuels on-site.

3. Data centres: Data centres form a large part of increased demand and therefore increased emissions. Data centre and large energy user connection policy should stipulate investment in both renewables and energy storage, and participation in demand response through load shed and energy storage. Data centre and large energy user connection policy should not allow installation of on-site fossil fuel generation as a way of reducing demand on the grid, as this increases emissions and locks society into fossil fuels.

4. Energy security and reliability: Capacity payments should consider local reliability and energy security, as well as national capacity/reliability. Capacity payments should incentivise investment in energy storage and dispatchable renewables and dis-incentivise further investment in fossil fuel generation. Non-firm connections should be offered to businesses involved in non-essential services so they can be cut off in the event of shortages.

5. Facilitating participation by households and communities in the energy transition.

5a. Right of grid connection for energy communities renewables: Energy communities are facing barriers in getting connection agreements for renewables projects from ESB networks. A "right of access" should be considered, in that communities and households should have as much right to generate energy using renewables as they have to use energy. Grid constraints should be addressed through sharing of maximum export capacity (MEC) at community level, and community level batteries and energy storage projects as collaborations between ESB networks and energy communities. Grid constraints should not entail refusal of connection agreements to community renewables projects or passing on large scale grid upgrade costs to community projects.

5b. Community batteries and energy storage: ESB networks should collaborate with sustainable energy communities (SECs) to implement community level battery schemes which facilitate grid stability, local balancing of demand and supply, and grid stability on the distribution grid.

5c. Cost reflective network tariffs: EU directives on cost reflective network tariffs should be implemented, in such a way as to incentivise and support balancing of demand and supply at local levels by communities

5d. Facilitate household and communities participation in demand response through a) market incentives: demand response market incentives, dynamic pricing options and b) standards for home energy management systems to be interoperable with heat pumps, charging of electric transport and other appliances.

PR5 DSO/TSO Joint Incentive Multi-Year Plan 2024-2028 Call for Input - Submissions

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