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The recent consultation by the Utility Regulator on the future of firm access raises important questions for renewable generators, investors and other stakeholders in Northern Ireland's electricity sector. At a time when dispatch down levels remain significant and major network reinforcement projects continue to face delays, the consultation considers whether the current firm access framework remains fit for purpose and how the interests of generators, network operators and consumers should be balanced going forward.
Why is the Utility Regulator reviewing firm access now?
Firm access is a market mechanism within the Single Electricity Market (SEM) that determines whether renewable generators are compensated when they are instructed to reduce output due to local network constraints, known as "dispatch down". Under the current Firm Access Methodology, introduced by SONI in 2011, renewable projects were permitted to connect to the network on a non-firm basis ahead of major reinforcement works, facilitating investment and renewable deployment on the expectation that subsequent network upgrades would provide firm access over time. While this approach enabled significant growth in renewable generation, many projects remain non-firm and therefore continue to bear the financial risk of dispatch down without compensation.
However, that position has become increasingly challenging in practice. Dispatch down levels have risen sharply in recent years, increasing from approximately 10% of renewable output in 2018 to a high of 25.5% in 2024 with levels remaining above 20% in the year to June 2026. At the same time, key reinforcement projects, including the North South Interconnector and Mid-Antrim transmission upgrade, have experienced significant delays. Therefore, with many generators unlikely to achieve traditional firm access until at least 2031, the Utility Regulator considers that a review of the framework is necessary.
What options are being considered?
1.1 Retain the current framework
The first option is to maintain the current arrangements. Under this approach, firm access would continue to be awarded under the existing methodology, with non-firm generators remaining exposed to dispatch down risks until the relevant network reinforcements are delivered. This option would avoid any immediate increase in costs for consumers as additional compensation payments would not be introduced. However, the consultation recognises that this option would not address concerns around delayed network reinforcements with no additional mechanism to improve accountability for the delivery of key infrastructure projects, would leave the current allocation of risk unchanged, and would not establish a formal timetable for reviewing the policy in the future.
1.2 Adopting the Irish approach
The second option would broadly align NI’s arrangements with the approach introduced in Ireland in 2023. Under this model, generators are awarded firm access where constraints at a node are 2% or below. Above that threshold, firm access is withheld pending delivery of identified network reinforcements, with the generator's position reviewed periodically. If those reinforcements are not delivered by an agreed date, firm access may nevertheless be awarded notwithstanding continuing physical constraints. The aim is to increase accountability for network delivery and share risk more evenly between generators, network operators and consumers.
While this approach may provide greater protection for generators, the consultation questions its suitability for NI given existing levels of network constraint and the potential for consumer-funded compensation costs to run into tens of millions of pounds annually, with considerable uncertainty as to future exposure.
1.3 A Northern Ireland-specific solution
The third option, and the Utility Regulator's preferred approach, is to develop a solution tailored to NI’s particular circumstances. Rather than focusing primarily on expanding compensation rights, this approach seeks to reduce constraints and improve the performance of the electricity system through a range of targeted measures as discussed below.
What is the Utility Regulator’s preferred approach and why?
The consultation suggests that simply extending firm access to a larger number of generators may not address the underlying causes of dispatch down. A key concern is that granting wider compensation rights without corresponding network capability could create what has been described as "financial firm access" rather than genuine physical access to the network. In those circumstances, generators may receive compensation even though the underlying transmission constraints remain unresolved.
The Utility Regulator also places significant emphasis on its statutory role in protecting consumers. Any expansion of compensation entitlements is likely ultimately to be funded through electricity charges, potentially resulting in increased costs for consumers. The consultation therefore considers a NI specific approach to balance the legitimate interests of generators with the need to avoid imposing disproportionate financial burdens on customers. Against that backdrop, this approach focuses on measures intended to improve system performance and reduce constraints, including:
What does this mean for renewable generators and investors?
The consultation recognises the challenges faced by generators operating without firm access, particularly where projects have experienced significant levels of dispatch down over prolonged periods. However, the direction of travel suggested by the consultation indicates that future policy may focus less on extending compensation rights and more on improving network efficiency and accountability. For existing generators, the outcome of the consultation could have important implications for future revenue certainty and project economics. For developers and investors, it provides a useful indication of how connection policy and network access arrangements may evolve in the coming years.
More broadly, the consultation highlights the growing importance of considering network constraints as part of project development and investment strategies. As NI continues its transition towards a more renewable-led electricity system, the interaction between network capacity, dispatch down and firm access is likely to remain a central regulatory issue.
Conclusion
The consultation provides an important opportunity to reconsider how the risks associated with network constraints should be allocated in NI’s electricity market. While it recognises the challenges faced by non-firm generators, the Utility Regulator's preferred approach points towards reducing constraints, improving network delivery and protecting consumers, rather than significantly expanding compensation rights. Ultimately, the consultation suggests that the key issue is not simply who bears the cost of constraints, but how those constraints can be reduced in the first place.
For more information, please contact Mark Stockdale, Partner, Nathan Moore, Solicitor or your usual ALG contact.
Date published: 15 October 2026
