The most recent Climate Action Plan 2024 has set an onshore wind target of 9GW installed capacity and 8GW of solar capacity. The Department of the Environment, Climate, and Communications (DECC) has run three RESS auctions already; however, the number of successful projects has fallen with each subsequent auction while the strike price has risen in each auction. This RESS 4 auction may be the penultimate opportunity to procure renewable assets if Ireland is to reach their ambitious CAP 24 targets, so participation and delivery are paramount. From an investor point of view, derisking projects and incentivising investment needs to remain the focus for the design of the terms and conditions for RESS 4.
The Electricity Association of Ireland recently responded to DECC’s public consultation on RESS 4 T&Cs and below are some of the main points that were made:
- Allocation of risks: the provision for “relief events” outside of the developer’s control was welcomed by industry. However, local network constraint risks are still being allocated to developers despite the developer being unable to mitigate or manage these risks. The EAI recommended that risks associated with these constraints should be placed with the entity best placed to manage them.
- Technology specific price caps: price caps should never act as a disincentive for viable projects to come forward if they are built at a fair market price. The parameters of cost and inflation that are used to calculate the price caps need to be up to date to reflect the real-life investment environment and should not be a theoretical exercise. The tweaking of the T&Cs to reduce developer risk should not be counteracted by unrealistic and penal price caps.
- Withdrawing from RESS: EAI members emphasised the need to maintain flexibility with regard to withdrawing from RESS. The RESS scheme is funded through the Public Service Obligation so a key objective for DECC is to ensure a fair price for the consumer. Not allowing a renewable project to withdraw from a government subsidy is at odds with that fundamental objective.
To read the EAI’s full response to the consultation, please follow the link below: