Response to Public Consultation on Article 26 of the Net-Zero Industry Act for ORESS Offshore Wind Auctions
October 2026
The MAREIRE project at the Environmental Pillar welcomes the opportunity to contribute to the Government of Ireland’s public consultation on Ireland's Article 26 of the Net-Zero Industry Act for ORESS Offshore Wind Auctions. The Environmental Pillar is a network of thirty eight national NGOs working to promote sustainable development and environmental protection. MARÉIRE, the “Marine Renewable Energy and the Irish Environment” Project, aims to advance and lead research, policy and advocacy in relation to marine biodiversity and offshore renewable energy (ORE), and to ensure that environmental protection remains at the forefront of decision-making, policy and planning whilst meeting our targets for renewable energy.
The Net-Zero Industry Act (NZIA), which came into force in 2024, introduced mandatory non-price criteria (NPC) in renewable energy auctions as defined by Article 26 whereby non-price criteria must be applied “to at least 30 % of the volume auctioned per year per Member State or alternatively to at least 6 Gigawatt per year per Member State”. Additionally, it specifies that “Member States shall give to each of the criteria to assess the auction’s sustainability and resilience contribution, when applied as award criteria, a minimum weight of 5 % and a combined weight of between 15 % and 30 % of the award criteria” for auctions developed under the EU State Aid Guidelines on Climate and Energy. This weighting can be exceeded in cases where the auctions do not receive public financial support.
We welcome the Government’s intention to apply Article 26 to all future capacity auctioned from 2026 onward. As NPC were required for auctions from 30 December 2025, their inclusion into auction frameworks is welcome and timely, and will not only improve and enhance environmental and social outcomes but will also result in reduced risks and improved public buy-in for projects. It is worth noting that many other countries have already introduced NPC to their auctions and, thus, there is no reason for Ireland to wait or phase their introduction. While we recognise that NPC should not drive up costs to the extent that they make auctions non-viable, it is however important to emphasize that, if designed properly and carefully, they can deliver multiple benefits for project developers, local communities and wider society, and contribute to a just transition.
