Since the liberalisation of Ireland's electricity system in around 2000, the policy around the allocation of grid connections has changed several times. In the latest major policy development, the Commission for Regulation of Utilities (CRU), Ireland's energy regulator, has proposed an Enduring Connection Policy (ECP).
A sudden stop
In order to prevent a "speculative rush" to submit connection applications or seek to relocate capacity, the ECP package included a direction, made by the CRU to the system operators on 2 November 2017, to suspend with immediate effect:
the acceptance of any new applications for the connection of generators or storage assets requiring capacity of more than 11kW the processing of connection applications that have been received but are not yet "in process", and the acceptance of any new applications for the relocation of connection capacity, and that involve relocation by more than "100 meters from the original site specified in the relevant application" While it may frustrate parties whose projects or transactions are directly affected, this standstill direction seems reasonable in order to give the CRU the breathing space to consult on, and implement, its proposed new connection policy.
The most significant aspects of the ECP are the proposals relating to the treatment of the connection applicants that are currently awaiting a connection offer. This is an enormous pool of projects, representing generation capacity in excess of 33GW, on a system that already has 10.8GW installed and has a historical peak demand of only 5.1GW.
Applicants with "live connection offers", and non-GPA applicants "in process", may transfer their connection applications into the new ECP process without first obtaining planning permission (which is otherwise a requirement for new applicants). Since the right of these projects to receive a connection offer does not seem to be affected by any transfer, the main purpose of this facility seems to be to allow projects to have their proposed connection methods revised by the system operators.
Applicants with less advanced connection applications, and those who have applied outside the categories of generator identified by the CRU for special treatment, may also transfer their connection applications into the new ECP process. However, in this case they are required to obtain planning permission, and they also run the risk of their application being deemed to be withdrawn if...