1. Introduction
Bord na Móna (BnM) welcomes the opportunity to respond to the latest consultation on the inputs and assumptions of the upcoming National Resource Adequacy Assessment (NRAA). We hope our contribution enhances the proposed methodology and contributes to the delivery of an assessment which will successfully measure resource adequacy and holistically capture risks specific to the Irish context. Alongside a substantial pipeline of development projects across a range of technologies, BnM operates a diverse fleet of generation assets which offer integral support to the Irish energy system. As a semi-state company, the interests of consumers is at the forefront of our future strategy. We therefore share the TSO’s dedication to providing a robust and secure energy system to meet user needs.

The NRAA will perform an important function in ensuring the long-term security of our energy system and electricity supply. The importance of its accuracy cannot be overstated, especially with the increasing electrification of many sectors of the economy. BnM recognises the challenge ahead for the TSO in advancing the grid to accommodate 80% renewable generation by 2030, alongside an energy demand increase of up to 43% . Achieving this requires a rapid increase in the current rate of renewable generation deployment. In a future system with up to three times more connected renewables, it is essential that the NRAA accurately captures all possible and unforeseen risks associated with a power system heavily reliant on non-firm resources.

2. Response
In our previous response, we emphasised various deliverability barriers and the uncertainties surrounding the pace at which new renewable generation assets will be operational. We are therefore pleased to see that future modelling will investigate a range of different levels of incremental renewables turning up year on year. Our response also highlighted the risks surrounding interconnector reliability and we therefore welcome this consultation’s inclusion of scenario modelling to investigate the impact of low import availability.
BnM largely supports the discussed data sources and views them as both appropriate and sufficient for holistically measuring resource adequacy. We also appreciate that many variables can exist within scenario testing and that a focus on ‘realistic’ demand scenarios is a most efficient use of time and resource availability. However, in the interest of enhancing the robustness of the NRAA, we see merit in the exploration of ‘extreme scenarios’ which still fall within the realm of possibility. Doing so will provide the most effective means of understanding what kind of back-up generation and responsive policy planning is needed under any level of system restraint.
In this vein, we are pleased to see that extreme climate conditions will be included in the assessment. While the year 2010 is a benchmark for particularly cold winter conditions, we believe climate assumptions should also be foresighted and that data inputs for extreme climate scenarios should extend beyond historical trends to account for climate change impacts. For example, while Ireland’s atmospheric temperatures have remained relatively steady across available data years, contemporary climate science points to a future risk of a considerable drop in temperatures should the Gulf Stream oceanic system collapse as a result of climate change. Due to proximity to the Atlantic, the Gulf Stream plays a key role in regulating Ireland’s climate. A recent study from the Irish Marine Institute reports that while a collapse is unlikely in this decade, a weakening of the system is underway. In the longer term, we believe a failure to analyse scenarios with unprecedented weather conditions risks a failure to capture the full extent of system pressures that could arise from prolonged periods of low temperature.

Finally, although insufficient data exists on outage statistics and battery storage is not at present considered for outage planning, we would encourage storage to eventually be included within the assessment as longer duration technologies become more available on the network.

We hope that EirGrid finds our contribution helpful and look forward to the final publication.

National Resource Adequacy Assessment Ireland - Inputs and Assumptions Consultation - Submissions

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