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Future of Ancillary Services in SEM: Final Design Considerations

 

In this latest ElectroRoute Insight, we delve into the recent SEM Committee final design decision on the Future Arrangement for System Services, which is a crucial element of policy required to incentivise the investment into and efficient operation of enabling technologies.

Background

EirGrid and SONI, the respective Transmission System Operators in Ireland and Northern Ireland, are each tasked with ensuring the reliable and secure operation of the power systems in Ireland and Northern Ireland. Central to achieving these standards is the existence of range of system services and reserve products (together known as ancillary services).

As the level of renewable penetration increases on the island, the importance of these services has materially increased. Via the launch of the DS3 programme initially in 2011, the island of Ireland became a test laboratory for much of the world regarding the procurement of services specifically to allow a high degree of instantaneous renewable penetration operate while maintaining system security.

The DS3 program has been essential in achieving 40% renewable energy penetration on the island of Ireland, however, the program was designed to meet the needs of Irelands power system in 2020. As we now look to 2030 and beyond it is imperative that the groundwork for a modernised electricity market, which promotes the transition towards flexibility and greater renewable energy integration, is actively prepared. Central to this is the shift from the current DS3 Regulated Arrangements to future competitive arrangements for the procurement of system services. The introduction of the Future Arrangements for System Services (FASS) program on the island of Ireland is essential for delivering a power system that can handle up to 95% System Non-Synchronous Penetration (SNSP).

FASS Design Decision

On the 18th December, the SEM Committee published[1] its final design decision for the FASS program. In this article, we share our thoughts on what is expected to be the biggest changes in the Irish market since the introduction of ISEM in 2018.

Initial Phase

The initial phase is focused on securing the key reserve services (FFR, POR, SOR & TOR) through a competitive daily auction process known as the Day-Ahead System Services Auction (DASSA). These actions will initially focus on procuring reserve services across the island of Ireland, meeting the jurisdictional requirements of both EirGrid and SONI. The auction will occur after the Day-Ahead (DA) market clears, with the regulatory authorities deciding to push the timing of the DASSA auction out to 15:30. This is something the industry will be extremely grateful for as it gives optimisers sufficient time to evolve their daily bidding strategy following the publication of the DA result.

The auction will secure system services over a 24-hour horizon, with the DASSA employing a pay-as-cleared model, settling prices for each 30-minute Trading Period, with auction winners receiving commitments for each period.

At first glance, there are many similarities between what’s being proposed in Ireland and what’s already in place in Great Britain’s ancillary services market. Opinions in the GB market vary widely depending on who you ask, but there’s no doubt that competitive auctions for ancillary services have opened the door for more participants, including renewable energy providers and battery storage operators.

This has driven down costs for consumers, but it’s also reduced revenues for asset owners who previously benefited from higher prices in a less liquid and competitive environment. The auction system has given National Grid ESO the flexibility to quickly adapt to changes in the energy mix, especially with more wind and solar in operations, and has kept the grid responsive to supply and demand shifts.

Further, competitive bidding in GB has made the process more cost-efficient and introduced innovative trading strategies to ensure new technologies such as battery storage take on a more prominent role, ultimately diversifying and strengthening the grid’s services.

Design Elements

The proposed design of the DASSA introduces several distinctive features that set it apart from the GB market. One key innovation is the inclusion of zero-volume bids and secondary trading, which allow renewables to take a more active role in the ancillary services market. This not only creates additional revenue streams for renewable projects but also enables traders to maximize returns by capitalizing on these new dynamics.

The introduction of a secondary market presents battery optimisers with significant potential to adopt dynamic strategies. By continuously adjusting an asset’s position within the revenue stack, they can ensure the asset generates the highest possible returns. This flexibility is key to staying competitive in a rapidly evolving market.

One of the biggest surprises in the regulators’ decision paper was the proposal to remove the Final Assignment Mechanism (FAM). The SEM Committee highlighted several flaws in the current FAM design, most notably its failure to incentivise ex-ante availability, a key objective of the original High-Level Design (HLD), a point we at ElectroRoute strongly agree with. Instead of driving proactive positioning by units, the FAM merely acted as a compensation mechanism based on units’ final positions at gate closure. Additionally, the inability to update bids closer to real-time made the FAM outdated and ineffective at capturing the true value of services.

While the SEM Committee believes that a fully automated secondary market and the removal of certain compensation protections will reduce the need for a top-up auction, we believe further consideration is merited here. Grid code requirements continue to mandate that all available units provide reserve during a frequency event, meaning that even unsuccessful DASSA participants serve as a backup and should be compensated if utilised. Although the FAM’s initial design had its flaws, we remain unconvinced that removing it entirely from the overall DASSA framework is an appropriate step.

Missed Opportunities

While the DASSA is poised to bring significant changes to the ancillary services market, there are some missed opportunities in the FASS program so far. The proposed products under DASSA offer limited innovation. Aside from the introduction of negative reserve products and the consolidation into a single replacement reserve product, there’s little variation in the reserve offerings for the initial implementation.

In contrast, the GB ancillary services market is continually evolving its reserve products to meet the changing needs of the power system, especially as renewable energy penetration grows. This constant adaptation ensures the market stays flexible and responsive to shifting energy demands. ElectroRoute suggest that a similar position is adopted on the island of Ireland

Another area where DASSA falls short is the proposed bidding structure, which lacks the complexity seen in GB. Complex bidding allows traders to adopt more flexible strategies, fostering greater competitiveness in auctions. In a market expected to be highly saturated from the outset, introducing complex bids would drive innovation and help secure the most competitive prices throughout the trading day.

Open Questions

While the work done by the TSOs and SEM Committee on the FASS program and the DASSA design must be commended, there remains a pressing need for clarity on several critical open questions. Chief among them is the interim arrangement between the conclusion of the DS3 program and the full implementation of DASSA. Given the industry’s experience with similar large-scale projects, delays are almost inevitable, and the lack of a clear transition plan could create uncertainty for market participants. It should be of no surprise that any potential cliff edge in the revenue model for market participants will severely impact the appetite for investment.

Conclusion

There’s no question that the ancillary service market in Ireland is on the cusp of significant change as it moves toward more competitive structures. However, somewhat sudden changes in the final design such as the removal of the FAM and a lack of clarity in other areas will add somewhat of a concern to participants. The industry will now look to the TSOs to provide clarity on the SEM Committee decision, which will provide much-needed certainty on several key issues that have are as yet unclear.

Additional consultation will no doubt be needed before we have a clearer picture of the full mechanics of the DASSA. The decisions made on the back of these consultations will not only shape the future of ancillary services but will also set the stage for how renewable and storage assets integrate into this evolving market. Ultimately, how these challenges are addressed will determine the success of DASSA and its long-term impact on Ireland’s energy landscape.

 

About Us

ElectroRoute is an active participant in the storage sector in Ireland, having contracted over 275MW of energy storage since 2021, and our storage and flex origination have considerable experience in the area of storage trading and operations. Should you have any queries, or wish to get in touch, please contact us at info@electroroute.com

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A Word of Thanks https://electroroute.com/a-word-of-thanks/ Fri, 01 Mar 2024 11:09:37 +0000 https://electroroute.com/?p=7058 […]

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A Word of Thanks

It’s been an amazing journey over the past 13 years.  While the pendulum of my focus must now swing to family and my personal life, I will forever be very proud of what has been achieved in ElectroRoute.

Saying goodbye is bittersweet, but it does afford an opportunity to acknowledge successes to date and wish everyone the best for the exciting chapters ahead.

Over the past couple of weeks, I’ve found myself reflecting a lot on the extraordinary challenges and achievements along the path of building ElectroRoute, from literally a set of ideas discussed for hours over kitchen and barroom tables in 2010 to what we have today.

The current range of activity of our pan-European trading company is wonderful.  A full end-to-end trading platform capable of scheduling electricity in a matter of minutes to trading natural gas many years ahead.  We’re shipping Biomethane through pipelines right across Europe one hand and underwriting the risks facing renewable assets for the next decade so that they can be financed on the other.  Since inception ElectroRoute as a company has been intent on knitting together the complicated threads of a decarbonised energy system.

I’m enormously grateful to Alex Bryson, Eamonn O’Donoghue, Alan Mullane, and Bernie Fitzpatrick – the steely co-founders who never wavered along the journey. Their fundamental belief in the mission of building a decarbonised energy system and the commercial opportunity that lay therein bound and fuelled the management team over the years.

While I’m stepping back myself at this juncture, ElectroRoute’s next phase is looking even brighter. Under the leadership of our new Co-CEOs Caoimhe Giblin and Donal Flynn, the company will benefit from vast experience and an expansive professional tool kit.  Two brains will certainly be better than one as the company drives confidently ahead.  I have always felt very privileged and humbled to count Caoimhe, Donal, and our HR director Catherine Kelly (all my professional seniors previously in Airtricity) as part of my team in ElectroRoute.

I have to suppress the temptation to elaborate endlessly in praise of the fantastic staff I have had the pleasure to work with, the friendly and open company culture we created and the innovative approach to technology at ElectroRoute. There simply aren’t enough words or time to do justice to the incredible people who have walked through our doors.  It’s been a great privilege working with each and every one of you across all locations, whether in Dublin, London, Tokyo, or of course, Donegal.

Great credit goes to our early-stage investors, central to whom were Paul Dowling and Bran Keogh. They helped us get on, and stay on, the right path. Over the past 7 years joining the Mitsubishi Group of companies has been instrumental in propelling ElectroRoute to its current significant European and indeed global footprint.  The scale, strength, and quality of our business today is testament to the invaluable collaboration and strength within the Mitsubishi family. That we now have a full suite physical and financial power trading platform operational and staffed in Tokyo is evidence of the potential for our collaborations in the years ahead.

The future is bright.  While I’ll be doing different things in the future, I am very excited to watch ElectroRoute continue to evolve and thrive under its new leadership. To everyone who has been part of this remarkable journey, thank you for making the last 13 years truly unforgettable.

Ronan

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New record for Irish Wind Generation! https://electroroute.com/new-record-for-irish-wind-generation/ Tue, 12 Dec 2023 16:01:07 +0000 https://electroroute.com/?p=6965 […]

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A record 4,629MW of wind power was generated in Ireland on 6th December 2023. This post from the ElectroRoute Trading team provides insights into the weather and system conditions that contributed to this impressive record.

On 6th December 2023, Ireland generated 4,629 MW of wind energy instantaneously, surpassing the previous record set in February 2022. This record, while another achievement for renewable electricity integration into the Irish electricity grid, was noteworthy for the ease that the Irish system was able to accommodate such high levels of wind generation, and this blog post explores some of the factors that contributed to that.

The high winds were caused by three low-pressure systems located directly off the west coast. Our generation forecasts at Day Ahead indicated that there would be over 4 GW of available wind for most parts of the day, with 5.3 GW possibly available around 14:00. Irish electricity demand was also forecast to be high over the day due to cold temperatures, peaking at 6.7 GW.

In GB temperatures were even cooler and there was lower wind generation, leading to high residual demand there. It was therefore likely that Ireland would be exporting for the whole day, and so it proved, as shown below.  These factors combined meant that the chances of large amounts of dispatch down of wind in Ireland were slim, and that the grid would remain stable even with a lot of renewable electricity generation.

The previous record wind generation of 4,610 MW was exceeded several times throughout the day, with Ireland’s wind generation peaking at 4,629MW at 16:00. Actual and predicted wind generation are displayed in the graph below (from EirGrid). For several hours during the day, the TSO accommodated more than 4.5 GW of wind power generation on the grid.

The below graph shows the wind output, the dispatch down and the “available wind” (the sum of output and dispatch down). Also shown below is a graph of the SNSP level over the day, taken from EirGrid’s dashboard. It is interesting to note that for such high levels of wind generation, there was very little dispatch down and SNSP levels remained relatively low, at just 60 – 65% during the period when generation was above 4.5 GW. The work EirGrid has done in allowing the SNSP limit to increase to 75% has meant that even during record wind generation, we had room to accommodate even more renewable generation on the system.

The SNSP level was helped as we were exporting power to GB. In a situation where we had in fact been importing power, a rough calculation would indicate that we could only have accommodated ~3.8 GW of wind generation on the system on the 6th December, highlighting the importance of increasing interconnection to Europe and GB if Ireland wants to meet its renewable energy targets.

This noteworthy accomplishment fits in well with Ireland’s renewable energy goals, which requires the country to produce 80% of its annual electricity demand from renewable sources by 2030, and with increased renewable generation capacity, further interconnection with GB & Europe and a continually rising SNSP limit, it is likely that Ireland will regularly break its wind generation record over the coming months and years.

As always, please get in touch with the ElectroRoute team of renewable energy experts for all your energy trading needs – info@electroroute.com

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ElectroRoute Provides Biomethane Services to DHL https://electroroute.com/electroroute-provides-biomethane-services-to-dhl/ Tue, 03 Oct 2023 11:37:46 +0000 https://electroroute.com/?p=6898 […]

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Introduction

This week saw an important milestone in the biomethane industry throughout Ireland with the announcement that DHL Supply Chain has agreed an €80M deal with Stream bioenergy which will fuel a fleet of up to 150 trucks for 10 years using biomethane as a source fuel.  DHL has teamed up with Tesco Ireland in the structure which involves 92 locally fuelled biomethane trucks for the retailer.

The news is important not just from the perspective of a major transport and logistics business outlining its intent to take a lead on decarbonising transport, but equally for a much-needed boost to the biomethane sector in Ireland. The Climate Action Plan (CAP) currently targets a 5.7TWh p.a. target in 2030 from an industry which is establishing itself from a relative standing start.

Figure 1: Pictured from L-R; Brian Kennedy (Head of Client Origination, ElectroRoute), Mick Kelly (Operations Excellence DIrector, DHL Supply Chain Ireland), Caoimhe GIblin (Commercial Director, ElectroRoute) [Conor McCabe Photography]

ElectroRoute’s Role

ElectroRoute is thrilled to have partnered with DHL in its journey to decarbonise its road transport fleet by providing a cross-border biomethane shipping and certificate management service which utilises our ISCC-certified European gas platform.

Through this cross-border biomethane shipping service, ElectroRoute has enabled DHL to immediately operate renewable-fueled trucks in Ireland. It takes time to deliver high-quality Anaerobic Digestion (AD) plants through the consenting and construction phases, and this innovative structure serves to allow a ramp-up in the fleet in advance of the indigenous solutions.

Over the last number of years, ElectroRoute has developed a comprehensive European platform which now sees us registered and actively trading on 14 cross-border interconnection points and operational in 11 European markets.

Through 2022, ElectroRoute flowed more than 2TWh of gas across Europe.

Moreover, ElectroRoute is accredited by ISCC to handle and ship biofuels throughout Europe. This unique platform means that ElectroRoute is positioned to act as a strategic shipper to Irish, European and multinational organisations seeking to transport and supply biomethane from source to use while crucially maintaining the green credentials of the physical biomethane.

 

Figure 2: ElectroRoute’s Gas Hub activity

Importance to Biomethane Targets

The Irish Government, and many others throughout Europe have identified biomethane as a carbon-neutral fuel which will act as a major source of decarbonisation for hard to electrify industries.

While the Government’s target of 5.7TWh production in 2030 (and up to 1TWh by 2025) is of course challenging to achieve in the time permitted, it equally should not act as a ceiling for our longer-term ambitions on the use of renewable gas on the island of Ireland. Gas Network Ireland, in its Gas Forecast Statement 2022[1], indicates a gas demand in the Republic of Ireland of 52.4TWh (all island demand of 72.9TWh). With the right balance of incentive and obligation, it’s entirely possible to look to the likes of Denmark which will likely achieve 100% of demand supplied with renewable gas between 2030-2035.

Importance of Biomethane in Transport

It’s clear that the transport sector needs broad-based solutions to support its legal requirements under the CAP Carbon Budgets, and while much hope is placed on the electrification of the broader transport fleet, it is widely understood that this will not resolve all transport emissions challenges. With hydrogen still in its infancy and, in Ireland at least, requiring major success in the cost of floating offshore wind as an input fuel, there is a need to emphasise the possibilities in other sectors. In Carbon Budget 1 (2021-2025), Ireland has already utilised circa 42% of its allowable budget of 50Mt CO2eq. in the transport sector.

It is important to note that at the end of a Carbon Budget cycle, we don’t start again from scratch but instead absorb any emissions which have overrun from the last completed budget. It is therefore critically important in all carbon budgets that policymakers do not make the mistake that the emission reduction effort can be rear-loaded. Any such delay in action will only serve to make the subsequent Carbon Budget more challenging to achieve. In the graphic below, the horizontal lines represent the total Carbon Budget 1 and 2, reflected in annual average terms.

Figure 3:Source: EPA

Should there be a budget overrun in Carbon Budget 1, then Carbon Budget 2 will automatically be set at a lower limit to counteract this. Biomethane offers a realistic prospect of supporting the decarbonisation of the heavy goods fleet in particular and doing so immediately. Initially, at least, this will be from certified renewable biomethane and subsequently from indigenous sources.

 

Contact Us

If you want to get in contact about Biomethane offtake or support in procurement and/or shipping, please reach out to our team at clientservices@electroroute.com who can support you.

 

About ElectroRoute

ElectroRoute is an international, renewables-focused, energy trading and services company. The company has grown rapidly from its establishment in 2011 to now employing over 120 professionals based in Ireland, the UK, Europe, and Japan.

The company’s vision is to make net zero a reality by solving the commercial mechanics of a decarbonised energy system. Its team of traders trade and optimise over 1.8GW of renewable and storage assets on a 24*7 basis using its unique, tech-driven, AI-powered platform, ElectroRoute CORE.

ElectroRoute operates a gas operations desk which ships biomethane throughout Europe on behalf of its client base, flowing more than 2TWh of gas in 2022.

[1] https://www.gasnetworks.ie/docs/corporate/gas-regulation/GNI-2022-Gas-Forecast-Statement.pdf

 

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Guest Blog: The Potential for Energy Storage in Ireland https://electroroute.com/guest-blog-the-potential-for-energy-storage-in-ireland/ Thu, 20 Jul 2023 14:05:14 +0000 https://electroroute.com/?p=6777 […]

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The State of Play for Energy Storage in Ireland

 

Energy storage is a critical enabler of our renewable energy transition, and its importance is starting to be recognised by stakeholders across the energy sector.

To date, the storage market in Ireland has been focused on short-duration lithium-ion batteries, that can provide the fast-acting backup needed to support the power system with growing levels of renewables. There are currently 670 MW of primarily short-duration batteries in operation on the island of Ireland.  These batteries contain frequency events by injecting power into the grid in milli-second timeframes. This has enabled EirGrid and SONI to reduce their reliance on fossil fuel spinning reserves allowing more space on the system for wind and solar generation.

The short-duration battery market is saturated at present so attention is turning to longer-duration batteries and other storage technologies that can provide additional benefits and capture other potential revenue streams such as energy arbitrage, peak shaving, capacity adequacy, congestion management etc. These longer-duration technologies will allow us to shift large amounts of renewable energy to help balance the system, reduce renewable dispatch down and provide an alternative to fossil fuels during times of low renewable output.

At ESI we carry out a pipeline survey of our members each year to understand how many energy storage projects are in development and what stage they are at. Our latest results as of the end of 2022 show there is a huge pipeline of just over 4,300 MW of battery projects in development with the majority already through the planning system and either in the grid connection process or awaiting the next grid connection round. These projects tend to be focused on durations of around 2 hours but the key benefit of storage is that it is flexible and can adapt to system needs and new business cases as markets develop.

 

How much energy storage will we need?

The battery storage deployed today is enough to meet Ireland’s short-term reserve requirements, but we are going to need a lot more energy storage from a variety of technologies with different capabilities by 2030. This will be essential to manage the large volumes of renewable generation necessary to meet our climate action targets.

In 2022, ESI carried out a piece of work with energy consultants Baringa to try and estimate how much energy storage might be needed by 2030 and what benefits it can bring to the power system and consumers. The output ‘Game Changer’ shows that energy storage can provide several major benefits besides providing zero-carbon reserve services.

Baringa modelled a 2030 Irish power system with high levels of wind and solar and compared a base case with no additional storage buildout than what is already connected today against multiple scenarios with an additional 2 GW of storage of different durations from 2 hours out to 100 hours.

The results show that the longest-duration energy storage technologies can reduce power sector emissions by up to 50% in 2030. This is particularly important because at this stage these residual emissions are the hardest to abate so energy storage plays a critical role in soaking up renewable oversupply and displacing fossil fuels at times of low renewable generation.

The study also showed that medium-duration storage (i.e. 2-6 hours duration) can play an essential role in providing quick-to-deploy peaking capacity solutions to alleviate short-term periods of congestion and system stress. These can help mitigate against volatile wholesale prices, particularly during winter periods.

Longer durations of 24 hours plus are particularly important for solving generation constraints and for absorbing renewable energy that would otherwise be dispatched down. These storage technologies can reduce dispatch down due to renewable oversupply by approximately 55% in 2030.

Finally, Baringa estimated that each of the storage scenarios would deliver a net economic benefit for consumers when taking into account the locational value of energy storage. This ranged from €30 million up to €85 million per annum in the longer duration storage scenario.

Baringa’s assumption of an additional 2 GW of energy storage by 2030 should be seen as the minimum we will need. More will very likely be required, mainly as we aim towards net zero. Putting the right market frameworks in place will be essential to ensuring investment in the quantities and types of energy storage that will deliver the best value to the system and to consumers.

 

Challenges and Opportunities

Delivering the volumes of energy storage we will need for 2030 and beyond will require coordinated policy action and specific market incentives to drive investment.

There are several existing market policies and systems which were designed around conventional generation and need to be updated to accommodate energy storage. For instance, the TSOs’ market systems are undergoing needed upgrades so they can more effectively utilise operational storage assets in the energy market.

Grid policy also needs to be updated to allow storage projects to connect to the system quicker and make use of their full operational capability. We are seeing that storage can face restrictions in terms of its ability to export or import at certain times. This needs more appropriate policy from the Regulators and System Operators to recognise the value storage can bring to the system as a flexible asset.

Right now there is no long-term investment signal for energy storage. The energy market is focused on short-term price signals and optimising the dispatch of generation and the DS3 market is moving this way too with the coming introduction of short-term auctions. The capacity market is the only market where storage can access long-term contracts, but storage is disadvantaged here due to de-rating factors and price caps designed around the costs of new gas generators.

Storage shares many of the same characteristics as renewable generation in terms of being a high capex/low opex technology but does not currently enjoy the benefits of having long-term investment support that is available through the RESS scheme in Ireland and the anticipated CfD scheme in Northern Ireland.

Things may be about to change with the ongoing EU market design reforms and the expected publication of the first national policy for electricity storage in Ireland later this year. In addition, we expect further progress on Northern Ireland’s Energy Strategy including a new route to market for renewables and supporting technologies.

This could see the introduction of new market frameworks for energy storage that allow multiple storage technologies to compete for long-term price support. ESI has produced a position paper on how this procurement framework might work including how different technologies could be valued for their contribution to the system.[1]

Ireland can continue to be a world leader in renewable integration by putting in place investment signals for longer duration energy storage as we increase our wind and solar energy and strive towards our carbon reduction targets.

 

Guest Blog is written by Bobby Smith, Head of ESI,

 

Energy Storage Ireland (ESI) is an industry representative association comprised of members who are active in the development of energy storage in Ireland and Northern Ireland. Our aims are to promote the benefits of energy storage in meeting our future decarbonisation goals and to work with policymakers in facilitating the development of energy storage on the island of Ireland. We represent over 55 member companies from across the energy storage supply chain. You can find out more about ESI by visiting www.energystorageireland.com or by contacting info@energystorageireland.com

 

[1] https://www.energystorageireland.com/wp-content/uploads/2022/11/ESI-Position-Paper-on-a-Procurement-Framework-for-Long-Duration-Energy-Storage.pdf

 

 

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Guest Blog: Recent Developments in Irish Offshore Wind https://electroroute.com/guest-blog-recent-developments-in-irish-offshore-wind/ Tue, 04 Jul 2023 14:23:32 +0000 https://electroroute.com/?p=6854 […]

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Continuing the ElectroRoute series of Guest Blogs, we are delighted to present an analysis of recent Offshore Renewable Energy developments in Ireland by Kristen Read of A&L Goodbody.

Since our last update in 2020, there has been huge change – and even some history made – in the Irish offshore wind sector, with momentum only continuing to build. This updated insight provides an overview of recent developments.

Passage of the Maritime Area Planning Act 2021

The Maritime Area Planning Act 2021 (the MAP Act) was signed into law on 23 December 2021. It provides new consenting processes for foreshore licences, foreshore leases and, importantly, planning permissions for various marine projects including offshore renewable energy infrastructure. It also creates a new regulatory authority and a regime for designating marine protected areas.  In particular, this ambitious legislation provides a “fit for purpose” mechanism for the consenting of offshore renewable energy projects in a way that complies with European environmental assessment obligations, facilitates Aarhus Convention-compliant public participation, and gives Ireland a realistic chance of delivering new renewable energy sources allowing it to meet its 2030 climate change targets. Some of the key changes are highlighted below:-

The Maritime Area Regulatory Authority

The MAP Act establishes the Maritime Area Regulatory Authority (MARA). MARA will have the power to grant Maritime Area Consents (MACs), discussed below and will take over responsibility from the Minister for Housing, Local Government and Heritage for the issuing of licences to conduct surveys in the marine environment (currently termed foreshore licences in Ireland). It will also have various enforcement functions. The MARA is currently set to be established on 17 July 2023. This will be a key step in the transition to the new maritime consenting regime and will be a key enabler in delivering Ireland’s ambitions for the Offshore Renewable Energy sector.

Maritime Spatial Planning and Designated Maritime Area Plans

The MAP Act expands on the existing regime for maritime spatial planning required under the European Union Maritime Spatial Planning Directive. The Government issued the first such spatial plan – the National Marine Planning Framework (the NMPF) – in the summer of 2021. The NMPF sets out various objectives and policies to guide activities and development in the offshore area. The MAP Act requires a review of the NMPF no later than six years following the publication of the first NMPF.

In addition, the MAP Act allows for the establishment of “Designated Maritime Area Plans” (DMAPs). DMAPs are specific parts of the maritime area that will be designated for particular “maritime usages”. On 10 March 2023, the Government published a policy decision entitled ‘Accelerating Ireland’s Offshore Energy Programme: Policy Statement on the Framework for Phase Two Offshore Wind’. This Phase 2 Policy Statement introduces a requirement that all future offshore wind farms must be built in DMAPs, which have yet to be identified. The approach to Phase 2 projects is discussed in more detail below.

Maritime Area Consent (MAC) regime

A MAC is a new “State consent” to allow for the occupation of a specified part of the maritime area. The previous equivalent was a “foreshore lease” and it is equivalent to a Crown Estate Lease in England. Such occupation may be on an exclusive or non-exclusive basis. Once established, MARA will be the authority responsible for determining MAC applications. Until then, the relevant Minister (the Minister for the Environment, Climate and Communications) has exercised MARA’s functions and powers in relation to the assessment of MACs. A MAC serves as the “gateway” into the development consent system. Developers are required to hold a MAC before they can apply to An Bord Pleanála for development permission.

The first seven MACs were issued by the Minister to the six Phase 1 offshore windfarm projects on 23 December 2022:-

  • Oriel Wind Park
  • Arklow Bank II
  • Dublin Array (comprising Bray Bank and Kish Bank MACs)
  • North Irish Sea Array
  • Codling Wind Park (Codling I and Codling II)
  • Skerd Rocks

This significant milestone for these six projects enabled all Phase One projects to begin their pre-planning application engagement with An Bord Pleanála which formally commenced in June 2023. The award of a MAC also enabled Phase One projects to participate in ORESS 1, the first auction for offshore wind under the Renewable Electricity Support Scheme (RESS) (see more details below).

Development Consent

The MAP Act requires specified categories of marine development, including, in particular, offshore renewable energy projects, to obtain planning permission under the existing planning legislation as amended by the MAP Act for that purpose.

An Bord Pleanála will be the decision-maker for offshore renewable energy project applications. The consenting regime is closely modelled on the existing consenting regime for onshore strategic infrastructure development, for which applications are also made directly to An Bord Pleanála.

Route to Market: ORESS 1 Auction Results

History was recently made with the running of the first Offshore Auction under the Government’s Renewable Electricity Support Scheme (ORESS 1). On 11 May 2023, EirGrid announced the following four projects as being provisionally successful under ORESS 1:

 

No. Project Offer Quantity
1.             North Irish Sea Array (NISA) 500MW
2.             Dublin Array 824MW
3.             Codling Wind Park 1,300MW
4.             Sceirde Rocks Offshore Wind Farm 450MW
  TOTAL 3,074MW

The final results were issued on 14 June 2023 and there was no change to the provisional results above. Therefore, around 3.1GW of capacity has been awarded. As such, additional offshore projects will be needed to meet the 5GW target of installed capacity by 2030. This transition from Phase 1 to the longer-term enduring offshore regime is referred as Phase 2.

Policy Statement on the Framework for Phase Two Offshore Wind

On 10 March 2023, the Government published its Policy Statement on the Framework for Phase Two Offshore Wind (the Phase 2 Policy Statement) which commits Ireland to meet its target of delivering 5GW of offshore wind capacity by 2030. The Phase 2 Policy Statement also notes that:

  • The development of Phase 2 projects will be dictated in large part by the availability of onshore grid connections. EirGrid analysis highlights the current availability of onshore grid capacity for further connection of offshore renewables of approximately 700MW in total off the south coast of Ireland.
  • This additional offshore wind capacity is intended to be split into two connections of 350MW each at two onshore locations along the south coast (this approach is stated to be subject to further clarification).
  • So, the first auction to take place under Phase 2 – ORESS 2 – will consist of 700MW off the south coast. However, recent statements from the Department of Environment, Climate and Communications suggest that the 700MW capacity available for Phase 2 Projects is likely to be increased to 900MW.
  • The location of offshore wind and offshore transmission system infrastructure for Phase 2 projects will be identified through forward spatial planning through the DMAP process. This is an important change from the developer-led approach adopted for the Phase 1 projects and will apply to ORESS 2 and all subsequent ORESS auctions. For the avoidance of doubt, all Phase 2 auctions will exclusively seek to procure offshore wind capacity located within offshore renewable DMAPs.

The Climate Action Plan 2023

On 21 December 2022, the Irish Government published its Climate Action Plan 2023 (CAP 2023), which is the second annual update to Ireland’s Climate Action Plan 2019. CAP 2023 is the first plan to be prepared since the enactment of the Climate Action and Low Carbon Development (Amendment) Act 2021 which places a legally binding objective on the State to pursue and achieve the transition to a climate-resilient, biodiversity-rich, environmentally sustainable and climate neutral economy by 2050.

CAP 2023 targets at least 5GW of offshore wind by 2030, and an additional 2GW of offshore wind for green hydrogen production.

What is to come?

The Phase 2 Policy Statement commits to a new Phase 3 which targets 2GW of floating offshore wind capacity to be in development by 2030. The longer-term ‘Enduring Regime’ for ORE will, according to the Phase 2 Policy Statement, involve greater State involvement in the sustainable development of the ORE sector, through:

  • further designation of maritime areas within which offshore projects will be developed;
  • the timing of future development; and
  • determining the optimum offshore renewable energy technology mix.

More information will be contained in the Offshore Renewable Energy Development Plan II (OREDP II) which is currently being developed by the Government, with public consultation having recently closed.

Offshore wind continues to represent an opportunity to not only be instrumental in Ireland achieving its 2030 target, but also to continue to send positive investment signals to the Irish market.

 

For more information please contact Kristen Read, senior associate on A & L Goodbody’s Environmental & Planning team or John Dallas, partner on A & L Goodbody’s Energy, Infrastructure & Natural Resources team.

 

Authors

Kristen Read
Associate
A & L Goodbody
John Dallas
Partner
A & L Goodbody

 

 

 

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