FOS welcome, and agreed with, the inclusion of offshore renewable energy (ORE) in the list of primary focus areas for 2024. EirGrid will play a pivotal role in the implementation of offshore wind, including an essential part in spatial planning such as Designated Maritime Area Plan (DMAP) site identification.

FOS support the recognition that collaboration across all sectors is critical to achieve Ireland’s Climate Action Targets (pg. 16). FOS also welcome the clarifications that EirGrid actively engages with the Government and regulatory authorities on key policies and strategic issues (pg. 21) and will be collaborating with, and co-hosting, public consultations with DECC in 2024 as part of the move to plan led approach for Phase 2 of offshore wind development (pg. 15). FOS believe these commitments are vital to ensure the long term success of the ORE plan-led regime.

FOS have a number of comments and recommendations in relation to engagement with ORE stakeholders to date (focusing on DECC and industry) and the proposed future engagement outlined in the Draft Stakeholder Engagement Plan (hereinafter referred to as the draft plan). Our key message is that significant and meaningful engagement between EirGrid, DECC and the ORE industry is urgently required via the following:

Open, collaborative dialogue with DECC on ORE development to ensure grid is not being developed in isolation to ORE policy and ORE site selection under the plan-led regime.
Consistency and alignment with DECC on policy and spatial planning. This is essential for stakeholders to understand proposals and respond accordingly to consultations and engagements.
Early and meaningful engagement with the ORE industry on plans and policy as the sector can provide valuable experience and lessons learned from other markets which will help decision making.

Addressing these points is vital to ensure investor and developer confidence in the Irish ORE market, which will be essential to achieve the 37GW offshore wind by 2050 target, and the interim targets, such as 20GW by 2040.

Working with DECC

Meeting the ORE targets requires simultaneous development of various policy, legislative and regulatory workstreams with input from numerous bodies. FOS welcome the steps outlined on pg. 21 of the draft plan highlighting the importance of regular engagement with DECC and CRU on key topics, including ORE transmission.

FOS have been disappointed in EirGrid’s lack of involvement during DECC-led industry specific workshops in 2023/2024, including an ORESS 2.1 workshop held on 26th July 2023, DMAP workshop on 8th September 2023, and ORESS 2.1 industry event on 15th January 2024. The commitment in this draft plan to collaborate and co-host events with DECC going forward is essential and should be made a priority.

FOS stress the need for collaboration with both DECC and industry to ensure grid is not being developed in isolation to ORE policy and site selection. In order to achieve this FOS suggest the following -

Continued, and enhanced, engagement between EirGrid and the Irish Government (including DECC who are leading the National Spatial Strategy and DMAP process) to ensure grid is suitably considered in long term ORE planning and that the grid and generation aspects of ORE designated area site selection, via the DMAP process, are aligned. This includes engaging with the ORE industry who can provide vital experience and lessons learned from other markets.
A clear and robust methodology to define DMAPs must be in place to ensure the most suitable sites are selected for each ORE development phase and associated auctions. Furthermore, it is essential that a single department leads the development of each ORE phase, including DMAP identification, grid proposals and linking to the wider industrial strategy, to ensure all of the policy objectives can be met. There are effective examples of this process from other markets, such as in UK where the Crown Estate leads the process, with detailed inputs from National Grid, Natural England, Natural Resources Wales, etc. This ensures consistency of approach and a clear pathway to delivery of a fit for purpose offshore wind model. FOS suggest DECC adopt a similar model with EirGrid being a key stakeholder inputting to the process.

With regards to the south coast DMAP process. FOS recognise the importance of ORE designated areas being geographically aligned with available onshore grid capacity, however, the offshore substation site (OSS) selection for ORESS 2.1 cannot happen in isolation from the South Coast DMAP process or offshore wind farm infrastructure locations.

FOS welcomed DECC’s clarification (during their ORE industry DMAP workshop on 8th September 2023) that the south coast DMAP process will be generation led. However, recent communications from EirGrid imply that the grid aspects of ORESS 2.1 have progressed ahead of / in isolation to DMAP finalisation and without adequate input from stakeholders, such as DECC and industry. Namely:

Section 2.4 of EirGrid’s Draft IP, notes that foreshore licences have been submitted to “inform the identification of suitable locations for offshore grid infrastructure” for ORESS 2.1.
A recent meeting between WEI and EirGrid (December 2023) indicated that a considerable amount of design work has been completed for the ORESS 2.1 grid scope.

As recommended by WEI’s grid optioneering paper (December 2023), the offshore grid connection method should respond to the ORE site selection and site layout process, allowing for optimisation of the grid assets within the windfarm site, as opposed to the ORE site being located to suit a pre-determined grid connection method.

Although landing sites are limited by onshore grid availability, FOS strongly caution against the OSS location being the driving factor for wind farm site selection. FOS urge EirGrid to work with DECC, and industry, during their grid optioneering process to ensure that any grid options being proposed consider the potential impacts on the offshore wind farm design. Even if DECC are leading this process, such commitments should be included in EirGrid’s stakeholder engagement plan.

DECC have previously confirmed that the study areas provided in EirGrid’s Shaping Our Offshore Energy Future and associated Foreshore Licence applications (FS007661 & FS007660) are initial areas only and do not signal that the location decision has already been made. FOS would, therefore, assume that the study areas detailed in the Foreshore Licence applications will be updated to align with the development areas identified in the draft DMAP (if necessary, noting that an application to MARA would be required should there be transmission infrastructure beyond 12nm). Clarification on this matter should be included as part of future stakeholder engagement.

Consistency and alignment with DECC

DECC and EirGrid must ensure consultation is consistent and aligned. This is essential for stakeholders to understand plans and proposals and respond accordingly to consultations, such as DECC’s upcoming Draft DMAP statutory consultation (currently scheduled for March 2024).

FOS note the following examples where there has been mixed messaging from DECC and EirGrid on key aspects of ORESS 2.1 / the south coast DMAP process. These aspects will significantly impact wind farm design and, therefore, auction bid price. Thus, meaningful, and productive engagement with DECC to agree such points is key. In addition, such misalignment must be avoided in future engagement for Phase 2 and all future phases.

Grid capacity: 900 MW has been quoted by DECC, whereas EirGrid have initially stated 700MW. FOS welcomed the clarification in Section 2.4 of EirGrid’s Draft IP that ORESS 2.1 will be up to 900MW off the south coast of Ireland. However, during the latest DECC meeting (15th January 2024), DECC indicated a 900MW non-firm connection. This presents risks to the ORESS auction. Consistency is required in all future engagements, consultations, and publications from the outset.
Development area: our understanding from WEI’s meetings with both DECC and EirGrid in December 2023, is that EirGrid’s preference is for ORESS 2.1 to be 2 x 450MW development areas whilst DECC’s is for a single 900MW site. Again, this shows misalignment. FOS caution against progressing with two development areas for a single 900MW project that is split across two separate sites. This creates increased complexity in relation to consent-ability, constructability and ultimately will result in a less competitive auction process. The ORE industry has valuable knowledge and expertise from other markets which can help inform DECC and EirGrid’s decision making process. Therefore, FOS strongly encourage more engagement ahead of the decision-making process between EirGrid, DECC and ORE industry to ensure the optimum solutions are chosen.
Timelines: the appendices of the draft plan state that the ORESS 2.1 Qualification Pack and Auction Information will be published in Q4 2024 (pg. 42 & 44 respectively). This does not align with DECC’s ORESS 2.1 indicative road map which has pre-qualifications as early as October 2024. Information packs must be issued in good time ahead of pre-qualifications to ensure developers can make informed decisions ahead of their bid. As mentioned in other consultations, a minimum of 4.5months must be allowed prior to auction for developers to evaluate the information packs.
Future publications: the draft plan appendices include the publication of “any additional EirGrid specifications identified for Offshore Developer-Led projects post Phase 1” (pg. 46). This contradicts communications from DECC on Phase 2 and beyond being wholly plan-led with development restricted to within DMAPs, only. This point has been raised previously with both DECC and CRU as the recent CRU Offshore Grid Connection Pathway for Phase 2 Proposed Decision also implied that developer-led merchant projects, post Phase 1, are possible. Alignment between EirGrid, DECC and CRU and clarification on this topic is imperative.

FOS would like to clarify that although the above primarily concentrates on ORESS 2.1, the focus should not only be on the near-term targets. Viable routes to market to achieve the 2050 targets are essential to ensure long term developer and investor confidence in the Irish market. A significant acceleration on the development of electrical grid infrastructure is critical; this includes the necessary stakeholder engagement to inform strategies, plans and policies.

The recognition of engagement via the Future Networks and Offshore Planning team (which focuses on the Future Framework) to develop further interconnection and the Offshore Blueprint 2040 Vision on pg. 25 of the draft plan is welcomed and must be implemented.

Engagement with Industry

FOS support the engagement EirGrid has undertaken with the ORE industry to date (pg. 24-25) and the proposed plans for 2024 including continued engagement with Phase 1 projects and increased engagement with regards to Phase 2 and beyond (such as engagement with the supply chain). FOS strongly support (and encourage more) continued collaborative, open dialogue with industry.

In addition, as noted above, EirGrid’s involvement within the relevant 2023 industry specific events chaired by DECC was lacking. Our understanding is that EirGrid indicated to WEI during their meeting in December 2023 that formal engagement on the south coast will commence in early 2024, this along with the WEI engagement to date is greatly welcomed and needed. However, there are no south coast offshore transmission infrastructure specific consultations, publications or engagements listed within the Appendices of this draft plan and FOS seek clarification on this.

Following feedback on the Offshore Renewable Energy Development Plan II (OREDP II, now known as the National Spatial Strategy) consultation period (February to April 2023), DECC introduced industry specific events as part of future ORE consultations. This was in addition to industry involvement in the Offshore Wind Taskforce. To date there have been three events – an ORESS 2.1 workshop held on 26th July 2023, a DMAP workshop on 8th September 2023 and ORESS 2.1 workshop held on 15th January 2024. The engagement has been well received. It allows for technical specifics to be discussed in more detail, for valuable experience to be shared and, importantly, for the public engagement sessions to focus on the local community.

FOS strongly encourage EirGrid to be more involved in these sessions going forward and introduce similar sessions for the ORE scopes they are responsible for. This would allow for a more open dialogue, which would be in line with the offshore engagement proposals detailed in the draft plan.

FOS support continued industry engagement, such as the meeting with WEI in December, however, as noted above, FOS have concerns that the proposals for 2024 are not sufficient. FOS request the following is considered in future ORE stakeholder engagement:

FOS seek to understand what grid connection options are being considered for ORESS 2.1 at this time and strongly encourage industry specific workshops on this matter in the coming months. The chosen option will have a significant impact on the windfarm design, and as such, industry is keen to ensure that any grid optioneering process also considers the potential impact on the connecting offshore windfarm design (including economic and deliverability criteria).
Some options may appear to be optimal when considering the high voltage grid assets only, however they may not perform as well when the windfarm is also considered. Optimising both the grid and windfarm asset design is necessary to ensure a cost effective ORESS 2.1 process.
FOS support the timescales shared previously by WEI on timelines for data sharing with industry stakeholders. As per the December 2023 optioneering paper, it is essential that developers are provided with clarity on the grid connection method (and grid capacity), costs and delivery timelines at least 4.5 months in advance of any auction so that impacts on the windfarm design can be considered and allowed for in auction bids. This information is critical for technical base cases, will inform bids, improve developer confidence in the windfarm preliminary design and reduce risk, ultimately leading to lower ORESS bids and driving value for the consumer.

Draft Stakeholder Engagement Plan 2024 - Submissions

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