The State is facing electricity outages next winter unless extra power stations are brought into service immediately, according to the ESB.
The effort by the Government to build electricity interconnectors to the UK by 2012 may not be met "given the progress to date", it also points out in a submission to the Government.
Efforts to encourage more private electricity into the market at the further expense of the ESB's share of the market must be curtailed, it claims. "The ESB has reduced its presence in the market to such a level that further reductions will impact on the ESB's ability to support the national interest, if required in the future," it adds.
The submission is a response made by the ESB to the Department of Natural Resources earlier this month, following the publication of a Green Paper on future energy needs in October.
Greater action to cut carbon dioxide emissions must be undertaken if Ireland is to meet international Kyoto treaty commitments, it says.
The Green Paper published by Minister Noel Dempsey, and which is to be followed by draft proposals early in the new year on Ireland's future energy needs, has placed "undue focus" on the electricity sector, the semi-State company complained.
Transport is "a significant and growing source of greenhouse gas emissions", while there is "a large potential" for energy savings from better-insulated and designed buildings, the ESB notes.
Given the commitments made by the Government under the Kyoto Protocol, the Green Paper "does not establish the measures to be adopted" to bring the CO2 curbs about, the ESB response claims. Carbon dioxide emissions must be cut, not just controlled if the State is to meet international targets. "It is clear that all sectors, including agriculture, must be involved in emission reduction efforts."
The Industrial Development Authority has warned that electricity interconnectors to the UK must be built at least two years ahead of the 2012 target. However, the ESB, in its submission to the department warns that meeting the 2012 target is "extremely challenging given the progress to date".
Rejecting charges that it has curbed the entry of private power generators, the ESB says it has met some of its commitments up to two years ahead of target.
Irish electricity generating prices are "systematically" above the EU's average because the country is heavily dependent on oil and gas, because it is a small market and because the population is thinly spread.
"While additional wind has a role to play, it is not a panacea as the cost of additional conventional back-up capacity must also be taken into account.
"Given Ireland's geography and policy decisions in relation to fuel sources, it will be difficult to bring generation costs towards the EU average, even in the long term," the ESB says.
Given the need to maintain secure supplies, the Government must take "no further action" to put coal-powered stations at a disadvantage.
A liquefied natural gas terminal, planned for the Shannon estuary despite local objections, would safeguard supplies, and help to protect the State from short-term shortages, it says.
Seeking clearance to build new plants, the ESB warns that some of its existing plants "are old, and at, or near the end of their economic lives".
The ESB says the creation of an all-island electricity market by November 2007 is "imperative", since it would allow for greater economies of scale.
