CRU Builds Upon the Reduced Planning Permission Requirements for RED III Projects

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CRU Builds Upon the Reduced Planning Permission Requirements for RED III Projects

May 8, 2025

As with the ECP-GSS (which we reviewed here), the Proposed Decision applies to onshore projects seeking connection to the electricity system.

It does not apply to interconnectors, demand connections, micro-generation, or offshore electricity connections.

Pre-Engagement Process

Per the ECP-GSS, before submitting its grid connection application, a RED III Project (i.e. renewable projects and co-located energy storage projects) must enter into a ‘pre-engagement process’ with the relevant SO in which the SO undertakes a ‘high-level technical assessment’ of the project. Grid connection applications may then be submitted prior to the planning permission being granted, once the relevant project’s planning application has been acknowledged as complete by the relevant planning authority.

The CRU proposal is that HLTA applicants will need to demonstrate sufficient project maturity in order to receive a HLTA. This could be shown through a valid planning application or a landowner consent declaration and a planning substantially complete declaration.

The output from the Pre-engagement Process is for a HLTA to be issued at least 30 days prior to the relevant grid connection offer batch closing deadline. This will provide information on the potential grid connection method, potential grid upgrades or reinforcements which will be required to connect the project to the transmission or distribution system, and an estimate of the charges associated with the connection.

The Proposed Decision sets out the CRU’s minded to position regarding the pre-engagement and HLTA process, including several changes from the ECP-GSS Decision.

Amended Timelines for Grid Connection Application Submissions

To reflect difficulties aligning the timelines for planning and grid permitting processes, the grid connection application will be submitted no greater than 15 calendar days following (i) the acknowledgment of a project’s planning as complete by the relevant planning authority as per ECP-GSS, or, (ii) the receipt of the project’s HLTA for the relevant batch, whichever is later. This second limb is a new addition set out in the Proposed Decision.

The timeline for the relevant SO to issue the HLTA is 30 days prior to each batch closing deadline. It is proposed that, for the initial 30 September 2025 batch closing deadline, the application for a HLTA must be submitted by 15 June 2025.

Amended HLTA Validity Duration for TSO Applicants

For projects applying to the distribution system operator (DSO, ESB Networks), the HLTA will be valid solely for applications to the first batch closing deadline after the HLTA is issued. For projects applying to the transmission system operator (TSO, EirGrid), the HLTA will remain valid for two batch closing deadlines. This is due to the larger numbers of expected applicants for connection to the distribution system, which necessitates the re-analysis of applications at every batch.

Non-RED III Projects

The Proposed Decision details the approach for non-RED III projects (i.e. conventional generation projects, energy storage projects which are not co-located, or other system services technology projects). There are a number of differences in the proposed approaches of the SOs, owing to the greater number of applications for connection to the distribution network compared to the transmission network.

Distribution System

In order to provide the DSO with oversight of the development pipeline and information on potential network interactions, Non-RED III projects applying to connect to the distribution system are required to pre-notify the DSO that they are intending to apply for their grid connection application. This notification entails:

Submission of a Pre-application Notification at least four months prior to the relevant batch closing deadline.
Application for planning permission and the inclusion of a planning reference from the planning authority, and expected date of grant of planning, to be included in the Pre-application Notification.
Payment of a non-refundable deposit (€7,000 or 50% of the connection offer application fee).

The DSO will carry out a high-level study of the relevant project to identify if there are network interactions between it and a RED III project. Where there are network interactions identified between a non-RED III project and a RED III project, the DSO will provide preliminary information about the connection method.

These projects will then follow the grid connection application and offer processes set out in Section 3.3 of the ECP-GSS.

Transmission System

Non-RED III projects applying to connect to the transmission system are encouraged to enter into early engagement discussions with the TSO.

These projects will then follow the grid connection application and offer processes for Non-RED III projects as set out in Section 3.3 of the ECP-GSS Decision.