RESS 3 – Provisional Auction Timetable Published

RESS 3 will be the third onshore auction run by the Irish Government under the Renewable Electricity Support Scheme. The auction is targeting the support of further onshore wind, solar and hybrid generation as part of the delivery of 80% of Ireland’s electricity from renewable sources by 2030 including up to 8GW of onshore wind and 5.5GW of solar generation capacity.

Provisional RESS 3 Auction Timetable

The Provisional RESS 3 Auction Timetable was published on 8 March 2023. It sets out the proposed dates for qualification, bidding and results announcement for the RESS 3 auction.

The key proposed dates and periods for RESS 3 are:

• Qualification application window: running from 10:00h on 30 May 2023 until 17:00h on 14 June 2023
• Provisional qualification decision date: 9 August 2023
• Final qualification decision date: 1 September 2023
• Bidding window: running from 10:00h on 8 September 2023 until 12:00h on 15 September 2023
• Provisional auction results date: 26 September 2023
• Final auction results date: 9 October 2023

For the moment, the provisional timetable will be sufficient for prospective applicants to plan their engagement with the process, ahead of the anticipated publication of the final RESS 3 Auction Timetable on 19 April 2023.

Terms and Conditions: still under construction

A limiting factor to any participation in the RESS 3 auction will be the fact that the Terms and Conditions that will govern the scheme have not yet been published, following the closure of a public consultation exercise on 16 December 2022.

The terms and conditions of the various RESS auctions have been the subject of vigorous industry debate since the publication of the RESS 1 Terms and Conditions in 2020. The RESS 3 consultation exercise suggested that the latest iteration of the scheme may differ from the earlier versions in the following areas, among others:

• Compensation for curtailment: adoption of a new “Unrealised Available Energy Compensation” (UAEC) methodology;

• Strike price indexation: unsuccessful requests for the indexation of strike prices were the dominant themes of discussions around RESS 1 and RESS 2. By contrast, for RESS 3 the Irish Government seems more open to accept a limited form of indexation, possibly through the use of industry-specific indicators such as the European Steel Index or the Non-ferrous Metals index;

• Price cap adjustment: the lowering of the highest permitted bid, in reflection of the de-risking represented by the UAEC and any upwards indexation of strike prices;

• Restricted ability to withdraw from RESS: possibly as a reaction to the number of supported RESS 1 and RESS 2 projects that are seeking to arbitrage between their secured RESS strike price and temporarily lucrative merchant trading, the government is considering requiring RESS 3 projects to remain within PSO (Public Service Obligation) payment structure for the entire term of RESS support – potentially depriving them of access to merchant prices;

• Corporate power purchase agreements (CPPAs): the government claims to be considering ways of providing, in the RESS 3 rules, “levers to stimulate supply of CPPAs”. This seems ambitious, given that in terms of the “routes to market” that are available to new renewable projects, RESS 3 generally competes with, rather than supports, CPPAs.

Next steps

RESS 3, the third iteration in the Irish Government’s support scheme for onshore renewable electricity generation, promises perhaps the most significant departure from the principles that have governed the previous auctions in the series.

Prospective participants should be aware of the provisional RESS 3 Auction Timetable, while also being mindful that both the timetable and the rules of the scheme remain subject to finalisation.

For more information and expert advice on RESS 3, contact a member of our Energy team.

The content of this article is provided for information purposes only and does not constitute legal or other advice.