The Council welcomes the opportunity to provide feedback to the ESB on its Transmission Access Reform Consultation Paper May 2022 (the Paper). The Paper shortlists options for reform of transmission access and management of transmission congestion. The ESB intends to prepare draft recommendations informed by feedback on and further assessment of these options, prior to submitting a proposed rule change to Energy Ministers by the end of 2022. The Council is pleased to note that key objectives of any reform include appropriate allocation of risks and, critically, providing a framework and signals for efficient investment which can provide the most benefit for consumers.