A Draft Risk Preparedness Plan for Ireland - Outcomes

Outcomes

The results of the consultation carried out and relevant updates made to the draft RPP are described below.

In response to points raised by EPUKI, additional clarity on the context of the AIRAA was added to Section 1.2(c) and in Section 1.4(e), minor changes to wording were made to aid clarity on the potential for concurrent scenarios.

Section 1.3 (f). Critical Entities Resilience Directive was included as a new section to the plan, following discussions with the TSO and consultee responses [Uisce Éireann and Energia]. The updates include, inter alia, (i) future engagements with critical entities identified through the CER, and (ii) references cross sectoral response.

Scenario 2.1 (c) Severe Storm, cross sectoral impacts on water and telecom systems were updated based on the recent Review of Storm Éowyn Report published by the Department of Housing, Local Government and Heritage (DHLGH), and to include reference to RES ramps, based on public consultation feedback [Uisce Éireann and NexSys – Nex Generation Energy System].

The scenario description for Scenario 2.3(c) Cyber-attack on entities not connected directly to the grid was expanded to describe the relevant entities, based on public consultation feedback [Energia]. Scenario 2.3 (d) Loss of ICT systems to cyber-attack has been updated based on feedback from the public consultation [Energia] to reference a cyber-attack on generators or producers, noting that the likelihood, impact and scenario rating are based on the reasonable worst-case scenario, which is considered to be a cyber-attack on the TSO control centre. Based on discussions with the TSO, the risk assessment for scenario 2.3 (d) Loss of ICT system to cyber??attack impact was updated, resulting in an overall assessment change to ‘High’ from ‘Very High’.

The scenario description for 2.4 (c) Grid Instability caused by unanticipated/uncontrolled interactions between new technologies was updated in relation to description, impact and mitigation, based on discussions with the TSO, and comment in the public consultation [Energia].

In the scenario 2.5 (b) Nuclear fuel shortage, following discussions with the TSO, the impact rating has been updated to align with the considerations of a comparable event in the AIRAA, but the overall rating remains unchanged.

In relation to Scenario 2.1 (f) Renewable Energy Source Shortage, including Dunkelflaute, additional context has been included, based on public consultation feedback [NexSys – Nex Generation Energy System], to the scenario evolution section in relation to the diversification of RES capacity and its role in strengthening energy security and system resilience.

In relation to measures, section 4.2 (f) (ii) Electricity crisis and climate change was updated by CRU in relation to climate adaptation measures for transmission and distribution systems, in the context of the recent publication by DCEE of the Electricity and Gas Sectoral Adaptation Plan.

The public consultation feedback [Energia and ICSF - Irish Climate Science Forum] included a point that there is an over-reliance on interconnectors as mitigation and energy security measures. Whilst not necessarily relevant to the RPP, we note that DCEE’s National Policy Statement on Electricity Interconnection 2023149 considers that “The primary drivers of Ireland’s interconnectivity needs are…. Ensuring electricity security and resilience through diversified energy supply and market access.” The AIRAA, which is referenced in the RPP, incorporates the impact of interconnection in its adequacy assessment, it “…accounts for the introduction of other non??conventional resources that can also supply electricity demand, including interconnection with Great Britain and France…”.

A consultee [EPUKI] raised point in relation to continued engagement around gas quality changes. CRU and GNI will continue to maintain ongoing engagement in relation to security of supply, including gas quality changes.

In relation to non-market generation, in discussions with DCEE, CRU included an update to the financial solidarity arrangements with IE and NI was included in Section 4.1(b).

Section 4.2 (b) (ii) Scenario specific measures Weather was also updated by CRU based on recent publications from DHLGH and ESBN relating to Storm Éowyn.

In relation to consultee feedback [EPUKI] regarding dispatch of non-market generation, additional clarity was included in Section 4.2 (c) (ii) ‘Temporary Emergency Generation’ 'Operational Treatment' in relation to conditions and notices for the issuing of a Margin Warning. Additional information was added to Section 4.2 (c) (ii) ‘Temporary Emergency Generation’ Transparency and reporting section summarising the number of issuances of margin warnings and margin shortfalls, and a summary of the TEG dispatch in May 2025.To Section 4.2(c)(ii) Retained Existing Units Reporting and transparency further clarity was added on the Margin Shortfall Risk issuance.

Section 5 Crisis Coordination was updated based on feedback from DoD and DCEE in relation to emergency response structures, and structures for coordinating risk preparedness, aligned with Strategic Emergency Management Guidelines.

Under the area of crisis coordination, a comment from the public consultation [Uisce Éireann] sought the expansion of notification processes beyond what is required in the RPP – the notification of entities when early warning or crisis declarations are issued, and not just the EC. This is not currently a requirement of the regulation. CRU carries out the early warning and declaration of an electricity crisis in accordance with Article 14(1) and (2) of the RPR. Public notification of early warnings and / or alerts would be assessed through the EPON, this reflects the importance of coordinated national communications in such circumstances. Agency social media channels would be available for such notifications.

We note that there are a number of publicly available notification channels in relation to system states, including the following. The SEMO website includes a dedicated section for Market Messages150, through which system states (including system margin warnings) are issued to inform stakeholders of emerging supply concerns. TSO social media would also notify followers of changes to system states. A further comment from the public consultation [Uisce Éireann] sought to expand emergency exercises to simulate cascading impacts on national critical infrastructure operators. This is outside the scope of the RPR, which is focused on electricity. The CER Directive has a focus on cross sectoral impacts.

A comment in the public consultation [Aggreko Ireland] referenced the review cycle of the RPP and its alignment with the NRA. The CRU, in collaboration with EirGrid, will undertake annual desktop reviews of the RPP and publish an updated version where an update is warranted. The public consultation highlighted some possible emerging scenarios [NexSys – Nex Generation Energy System and Confidential response], these and other emerging scenarios will continue to be assessed as part of the regular RPP review process.

The final Ireland's Electricity Sector Risk Preparedness Plan (2026-2029) has now been published on the  CRU web site. Click here to access it.