Key Contact: Niall Donnelly – Partner |

On 3 March 2025, the Commission for Regulation of Utilities (“CRU”) published a consultation paper on the dynamic sharing of maximum export capacity (“MEC”) behind a single connection point (“Consultation”).

Hybrid projects combine two or more types of electricity generation and/or storage units connecting to the grid through a single connection point. The benefits of hybrid projects are not fully realised currently as such projects are unable to dynamically share a MEC between the different assets behind the single connection point. If the MEC is determined at the connection point rather than at the unit level, it would enable more efficient use of the connection point with the MEC being used by the generation units according to resource availability (e.g., switching between wind and solar) and may reduce the need for additional grid infrastructure to support the build out of new capacity at the site.

Industry has sought reform of this area for some time and the publication of the Consultation is a welcome development. We highlight some of the key features of the Consultation. The Consultation is open for comment until Monday, 14 April 2025.

CRU’s Proposal On MEC Sharing

  • Definition of hybrid projects. The CRU intends to limit the proposal to onshore hybrid co-located projects. These are projects that combine multiple forms of generation and/or storage technology behind a single connection point. These differ from integrated hybrid projects, which are multiple generating units which utilise multiple primary energy sources or technology types and are registered in the market as one single market unit.
  • Proposal for sharing MEC behind a connection point. The units behind a single connection point would operate as separate units for the purposes of scheduling and dispatch, market participation and system services (and would have sub-meters). However, the MEC would be summed at the connection point, and there would not be a unit level MEC. With respect to the sharing of the MEC for the purposes of the market, the System Operators have set out two options (which will be explored in the implementation roadmap to be developed by the System Operators):
  • Option 1: Registering all generator units under a single trading site; or
  • Option 2: Registering each generator unit under separate trading sites.
  • Managing the MEC. The export from the hybrid co-located site would not be allowed to exceed the MEC at the connection point. The party managing the market participation of the units would be left to determine how the MEC is used between the units at the site, subject to the market rules.
  • Amendments or new connections. Where an existing connected project seeks to add another technology type to their connection to become a hybrid project and no increase in MEC is required, it will apply through the Modifications to Generation Connection Offers process. Hybrid projects seeking a new connection or an increase in MEC will be required to apply for grid capacity through the process outlined in the ECP-GSS decision.
  • Different legal entities. The Consultation only applies to a single legal entity behind the connection point and does not provide for multiple legal entities behind a single connection point.
  • Technology types. The CRU does not propose to limit the sharing of MEC to specific generation or technology types at this time.

Possible Impacts Of The Proposal and Changes Required

The Consultation explains that the System Operators have identified several areas that need to be reviewed in advance of the potential introduction of a policy on MEC sharing. An implementation roadmap will be published alongside the CRU decision paper which sets out actions and timelines to implement the proposal. Possible changes could include:

  • Financial securities. New processes for determining and processing the connection charges bond and capacity charges bond.
  • Connection Agreements. Amendments to standard connection agreements to facilitate the sharing of MEC.
  • Network planning impacts. More detailed technical studies, which would be carried out on hybrid sites and technologies to understand their technical and dispatch profiles (including potential impact on dispatch down levels).
  • SEM Energy market impacts. SEMO and the TSO may identify necessary modifications to the Trading & Settlement Code to fully account for sharing of MEC.
  • Capacity market impacts. The eligibility for generation/storage units within co-located hybrid projects to qualify for participation in the Capacity Market auctions could be considered by the TSO and their “de-rating factors”.  
  • Tariffs, Levies and Charges. A review of the calculation of tariff arrangements around GTUoS, DTUoS and the PSO levy.
  • System Operations Impact. Various operations of the System Operators may require updates to facilitate the sharing of MEC.

Next Steps

The CRU will assess stakeholder support for this proposal. Assuming the response is positive, the CRU will engage with the System Operators to develop the requirements and timelines associated with facilitating the sharing of MEC at the point of connection. The CRU will then publish a decision paper, alongside a roadmap and implementation plan developed by the System Operators.

If you require any further information, please contact a member of our team below.

Key Contacts