Page Contents
Related areas
Key contacts
First published by Energy Ireland in their annual yearbook this month.
The opportunity
In January 2025, installed Irish wind capacity reached the 5GW mark – over halfway to the 9GW 2030 Climate Action Target. To date this wind capacity has been delivered by greenfield renewable developments, but if Ireland is to achieve its 2030 targets then maintaining its existing windfarm generation fleet will need to become a part of that story.
Wind Energy Ireland commissioned a study in 2024 which found that ~ 850 of the 4,347 MW of installed wind generation will either reach the end of its operational planning permission or need to be decommissioned before the end of the decade.
As companies decide how to manage their ageing wind assets – whether through decommissioning, life extensions or repowering – there will be opportunities for developers, investors and the wider supply chain to help sustain Ireland’s progress towards ‘net-zero’.
Directive (EU) 2023/2413 (“RED III”) sets an EU-wide target of 42.5% for renewable energy consumption by 2030. It aims to simplify and accelerate the permit-granting procedures for renewable energy projects and necessary supporting infrastructure. Repowering is a key focus of RED III. It defines the timeframes for the permitting of repowering projects – either taking up to three, six or 12 months, depending on the nature of the project.
Key considerations
Asset owners’ strategies will be site and asset specific. Owners will need to analyse the existing property, planning and grid connection solution for each of their assets.
Extensions of existing property rights – leases, rights of way and wayleaves – may be required, including an assessment of the duration, renewal rights and project descriptions in each of those documents. New land options and leases and other property rights may also be needed depending on the complexion and footprint of any proposed (re)development.
Where developers are looking to extend the operational lifetime of a project, a planning application will need to be submitted before the expiry of the operational period. The planning authority will be required to make a decision based on the law, guidelines and policy in place at the time of application. Any changes to zoning, designation of protected habitats/species, and the results of environmental screening/assessments will all need to be considered in any decision to extend the operational life.
Planning permission will be required to repower a wind farm. A planning application will need to be made to either the local planning authority or An Bord Pleanála. Planning applications will also likely require an Environmental Impact Assessment and Appropriate Assessment, depending on the nature and scale of the development. RED III institutes a presumption that renewable energy projects and the related grid infrastructure are in the overriding public interest. This presumption should help repowering projects to overcome spatial planning policies which have now deemed areas with operational wind farms as less suitable or not suitable for further wind energy development.
The Commission for Regulation of Utilities (“CRU”), the Irish energy regulator, published a decision paper in September 2024 setting out the new connection policy for generating assets in Ireland (CRU2024101). This decision includes specific consideration as to how the system operators, being EirGrid and ESB Networks respectively, should assess applications for ‘repowering’ of renewable projects.
The CRU considers that the timelines detailed in RED III are applicable to both refurbishments/extensions of a plant (i.e. where upgrades or replacements of necessary parts of a plant take place to enable it to operate beyond its original design life) and full repowering (i.e. where a plant is decommissioned and replaced with a larger plant). The assessment process and timelines will differ depending on the size and technical and safety requirements associated with the individual project. In general, however, the system operators will be required to make decisions within a three to 12 month timeframe.
Looking forward
In addition to property, planning and grid, asset owners will need to make strategic decisions regarding turbine replacement/maintenance, potential civil and electrical works, route-to-market and financing options, while also weighing potential M&A opportunities.
Industry, regulators and administrative bodies should watch closely as practical experience from other EU jurisdictions emerges. As with other areas of renewable energy development, consistent EU and domestic policy and legislation will help advance Ireland’s ability to maintain its existing infrastructure.
For more information please contact John Dallas, partner, or a member of the Energy, Infrastructure & Natural Resources team.
Date published: 19 May 2025
