Electricity Grid: Reminder that Firm Access Consultation closes on 8 November 2022
To facilitate delivery of new generation projects, grid operators may offer to connect new plant to the grid pending completion of required network reinforcements. Though a generator may be constrained down because of local grid congestion, there is an entitlement to be compensated for resulting lost output under the SEM Trading & Settlement Code, but only where and to the extent the generator has a Firm Access Quantity in its connection agreement. Under the interim approach to applying Article 13 of the IME Regulation in Ireland (see decision here) compensation for curtailment will also be subject to Firm Access.
The most recent Annual Renewable Energy Constraint and Curtailment Report indicates that, in 2021, levels of dispatch down of wind energy as a percentage of total available energy from wind was 7.3% in Ireland (7.4% in the SEM). The Regulatory Authorities indicate that approximately 18% of connected renewable energy is non-firm.
Currently, the date on which generators are guaranteed to receive Firm Access is tied to completion of Associated Transmission Reinforcements (ATRs) by EirGrid. This can lead to uncertainty which impacts the cost of new project delivery. There are Clean Energy Package obligations in this area, with regulatory authorities required to ensure that any limitations in guaranteed connection capacity or offers of connection subject to operational limitations are introduced on the basis of transparent and non-discriminatory procedures and do not create undue barriers to market entry.
Proposal for a new Firm Access policy
EirGrid has proposed a new Firm Access policy which, significantly, would de-link the guarantee of Firm Access from the date of completion of ATRs. Instead, projects would be given time bound dates by which they would get Firm Access.
Another significant aspect of the proposal is that Firm Access would be allocated in annual review processes. Firm Access would be available to connected and committed generators where analysis shows constraints are expected to be below a ‘Firm Threshold’ in a given year. (‘Committed’ indicates getting beyond ‘Consents Issue Date’ under EirGrid Conditions of Connection & Use of System.) Those in areas where the EirGrid Transmission Development Plan indicates there will be future capacity would be allocated a future date for Firm Access. Where a generator cannot be given Firm Access for its total Maximum Export Capacity, partial Firm Access in blocks of 20 MW would be considered.
The proposal raises numerous practical questions in respect of which further detail is needed, including how Firm Thresholds would be set, and at what stage projects seeking connection to the distribution network would be considered to be committed.
However, the prospect of moving to a policy that provides certainty around the date by which a project has Firm Access, along with a regular review process, is positive. If implemented effectively, it could help deliver the renewable generation capacity needed for decarbonisation and security of supply. Timing wise, the benefit of this approach would be better realised if guaranteed Firm Access dates were known in time for projects to prepare their RESS auction bids.
The consultation is available here and closes on 8 November 2022.