The ECP-GSS will open twice every year. There will be a first “Batch Closing Deadline” on 30 September 2025, and then 31 March and 30 September each year. Caps have not been set on numbers who may apply, but that could be reviewed. The full policy is available on the CRU website here.

Pending implementation of the new policy, there will be a last annual application window from 1 October to 30 November 2024 (ECP-2.5)).

An objective of the policy is to meet the timelines in which ‘permit-granting procedures’ must be carried out under the EU Renewable Energy Directive (“RED III”). Under RED III, a permit-granting procedure includes (among other elements) all relevant administrative permits to build, repower and operate renewable energy plants and co-located energy storage, including grid-connection permits and, where required, environmental assessments. A permit-granting procedure comprises all administrative stages, starting from acknowledgment of completeness of an application (which must be done within certain time limits) and finishing with notification of the final decision.

There are timelines for ‘permit-granting procedures’ onshore and offshore, in renewable acceleration areas and remaining areas. For example, the permit-granting procedure outside renewable acceleration areas cannot exceed two years for renewable energy projects, and 12 months for repowering of renewable energy power plants and for co-located energy storage (subject to some caveats).

Bi-annual Batch Processing

Under ECP-GSS, the CRU sets out processes for projects it describes as ‘RED III Projects’ (renewable projects and co-located energy storage projects) and ‘Non-RED III Projects’.

• ‘RED III Projects’: These projects must enter a “Pre-engagement Process” with the relevant system operator (“SO”) several months before the Batch Closing deadline. To submit an application for connection, applicants must: (a) include the outcome of the pre-engagement process, namely a “High-level Technical Assessment” (“HLTA”), and (b) provide evidence that the planning authority has acknowledged that a planning permission application that has been made is complete. The CRU is requiring that the application for connection is submitted “not greater than 15 calendar days following a project’s Planning Application being acknowledged as complete by the relevant planning authority”, in ease of competent authorities meeting the permit-granting procedure timelines in RED III. The CRU’s view is that, if the applicant misses this 15-day window (or decides to wait to obtain full planning permission), the overall permit-granting procedure timelines “might cease to apply”, the applicant being “deemed to have opted out of the RED III” timelines. The CRU considers that the SOs would still be required to process the connection application within 12-months of the Batch Closing Deadline.
• ‘Non-RED III Projects’: These projects must obtain planning permission before submitting an application for connection.

On receipt of an application for connection, the SOs are to confirm whether the application is valid or invalid within 45 calendar days. Following the Batch Closing Deadline, batches will be formed (over the course of 45 calendar days), and valid applications will be deemed “Batch Qualified”.

The CRU indicates that SOs will process offers within 12 months from the Batch Closing Deadline for renewable projects, and 18 months from the Batch Closing Deadline for conventional projects.

The applicant has 60 calendar days to accept the offer, failing which it will lapse. The applicant must have received planning consents before accepting the offer.

Batch Processing will also apply to some categories described further below, and to autoproducers.

Repowering of Renewable Projects

In addition to setting a 12-month permitting timeline for repowering, RED III provides that, where repowering does not result in an increase of the capacity of a renewable energy power plant beyond 15%, permit granting procedures for connections to the grid shall not exceed three months following application unless there are justified safety concerns or there is technical incompatibility of the system components.

The CRU has based the approach on whether change is sought to the Maximum Export Capacity (“MEC”) in the Connection Agreement:

• No MEC increase: The existing Modifications to Generation Connection Offers process will apply. The connection offer is to be issued within three months of acknowledgement of a valid application, unless the SO identifies justified safety concerns or technical incompatibility of the system components, in which case the offer is to issue in nine months, subject to resolution of the safety concerns or technical incompatibilities.
• MEC increase of less than 15%: The project will enter the Pre-Engagement Process. If this does not identify safety concerns or technical incompatibilities, the project will apply for a connection outside of the batch process, and the offer is to issue within three months. If safety concerns or technical incompatibilities are identified, the project must apply into the Batch Process (being treated as a renewable project), and the offer is to issue within nine months.
• MEC increase greater than 15%: The project will enter the Pre-engagement Process and apply in the Batch Process. The connection offer is to issue within nine months.
  

The applicant has 60 calendar days to accept the offer. Planning consents must be received before the offer is accepted.

Storage

RED III defines ‘co-located energy storage’ as an energy storage facility combined with a facility producing renewable energy and connected to the same grid access point.

The CRU indicates that:

• co-located energy storage on existing renewable energy sites will follow the process for ‘RED III Projects’, described above, and be issued within nine months of acknowledgement of a valid application,
• energy storage projects which are not co-located will follow the process for ‘Non-RED III Projects’, described above, and
• new hybrid projects comprising a mix of renewable energy technologies or renewable energy combined with co-located storage will be treated as ‘RED III Projects’, required to apply through the Batch Process.

Capacity Market and Systems Services

Projects that have been successful in the capacity market will be expected to apply for a connection through the ECP-GSS batch process.

This is a departure from current practice where the CRU issues a Security of Supply Direction to offer connection to projects which are successful in a capacity auction. The CRU states it reserves the right to issue such directions, but anticipates that they will not be issued for the purposes of a T-4 2031/2032 auction or beyond.

Specific details are set out for ESBN Demand Flexibility Products and Low Carbon Inertia Services, as well as the Fixed Arrangements framework for system services (SEM-21-021). The CRU anticipates that system services procured in other ways, currently under development (such as daily auctions), will apply to be Batch Processed in ECP-GSS.

Firm Capacity

The extent of MEC that is ‘firm’ underpins certain entitlements to compensation for downwards dispatch. Under the firm access policy approved by the Single Electricity Market Committee, EirGrid will carry out:

• an annual Firm Access Allocation Run with results expected in Q1 2025, and
• bi-annual Firm Access Allocation Runs, with results to be published within five months. The run will be based on a 30 September 2025 freeze date. After that, freeze dates will be 31 March and 30 September each year.

The new ECP-GSS also addresses community-led projects, as well as mini-generation, small scale generation and non-exporting generators.

Next Steps

The SOs are to propose further details of Pre-Engagement and Batch Processing in January 2025. In addition, EirGrid is expected to:

• update charging and rebating methodology (Q4 2024),
• engage with industry to prepare a proposal for updated constraints reporting (Q1 2025), and
• propose locations which may be suitable for Renewable Hubs.