How did we get here? A review of recent changes to connections policy

00:00:53 – Pete Aston
Hello and welcome to another episode of Roadnight Taylor’s ‘The Connectology’ Podcast. I’m joined today by Nikki Pillinger and Catherine Cleary, so welcome both.

00:01:02 – Catherine Cleary
Hi Pete.

00:01:03 – Nikki Pillinger
Hi Pete.

00:01:04 – Pete Aston
There has been absolutely loads going on in the connection space over the last couple of years and it’s time to perhaps draw breath and have a look back. It’s very easy to get caught up in the moment with everything that’s going on right now with Connections Reform, but there’s been an absolute load that’s gone on in the last couple of years. I think it was just worth reflecting on seeing if any of them have actually done anything useful, looking at the impact of them, and then we’re going to spend a few minutes at the end just looking at what’s coming next and to see if we can set the scene for the rest of 2024 and into 2025.

The first thing that we want to pick up on and go over to Nikki for this – can you just talk us through the growth of applications and especially the growth of the transmission queue over the last couple of years, because that’s really what’s driven a lot of the issues.

00:01:50 – Nikki Pillinger
Yes, of course. So, this kind of goes back a little way really, so during the days of when we had subsidies, we had quite small distributor generation, so a lot of it would be sort of 11 or 33 kV connected and maybe 5, 10 megawatts, not too big. Then, after the subsidies ended, developers sort of started looking at larger projects, so a lot of like 50 megawatt projects at 132 kV. This actually then started to fill up the distribution system quite quickly.

At the end of the subsidies, distribution customers started looking at much larger connections to make connections viable (subsidies ended in 2017) and started looking at sort of larger products like 50 megawatts at 132 kV was quite a popular application, and this actually then started to fill up the distribution system quite quickly. So, from about 2020 onwards, people then started getting Mod App results back that were coming back with what we then thought was quite ridiculous dates. 2028 actually sounds like quite a reasonable connection date nowadays, and people were also setting their sights on transmission connections as well to get even more economies of scale.

However, what this did was it filled up the distribution system quite quickly, so people would start getting quite a lot of transmission reinforcement, quite a lot of ANM associated with that connection, so people then started going straight to the transmission system to apply and this caused a kind of an explosion that was quite unprecedented in terms of applications and in terms of contracted capacity.

So, I don’t have the exact numbers in front of me, but last look it was about 700 gigawatts of contracted connections in the queue. There’s about 150, 160 gigawatts of distribution connections. Last official sort of figures I heard from Solar and Storage were that we had five times more solar, five times more storage than we actually needed to get to net zero by 2050. So a huge amount of distributed generation. So, this is kind of the problem that we have at the moment is that we don’t need all of this contracted generation; yet we had a system that we have to run, or design as if this generation is going to go ahead. So this is what Connections Reform is trying to tackle now and this is what a few other initiatives of a little while back tried to look at and solve.

00:04:19 – Pete Aston
Thanks Nikki. And Catherine, just to bring you in because you’ve probably been doing transmission applications longer than any of the rest of us have in Roadnight Taylor.

So, what was life like in the transmission space prior to this explosion of transmission applications, sort of three or so years ago?

00:04:38 – Catherine Cleary
The TEC queue was probably maybe less than 200 gigawatts back then and I suppose the important point was it wasn’t growing super rapidly. So, we used to see about 100 to 300 offers per TO, so across NGET and the two Scottish TOs come out per year – that has changed significantly and we’re now, that’s multiplied by a factor of at least 10, I believe, in total since about kind of 2021, 2022. The kind of volume of offers being released has exponentially increased and that obviously has driven the increase in the contracted capacity that Nikki mentioned there as well.

00:05:16 – Pete Aston
You know, I think it’s often quite easy to point the finger at the ESO and the TOs and sort of criticize on processes and so on. It has been a really significant step change in what they were used to, wasn’t it?

00:05:29 – Catherine Cleary
Exactly. I think the other point is probably that those applications came from a very small pool of customers. You could get all of the companies in one room you know who have existing energised transmission connections and were kind of used to applying for transmission connections. So, effectively, the ESO saw a huge growth in customers, but from entirely new customers, as Nikki said, a lot of parties who had been used to looking at embedded schemes, distribution schemes, solar storage schemes, who had no experience of ESO connections. I think that’s a challenge for anyone to face.

00:05:59 – Pete Aston
Building on from that, there’s the issue of educating a whole new group of developers. Isn’t there, in terms of how transmission applications work?

00:06:09 – Catherine Cleary
Educating them and also deciding how you’re going to engage, and I think that’s probably one of the things which has been the biggest shift is a need to perhaps formalize some of the policy bait which were effectively kind of bilateral discussions in the old days. You know there wasn’t quite so much concern around you know, are you treating everyone, you know, absolutely uniformly, because it was recognized, you know that perhaps one nuclear power station wasn’t the same as an offshore wind farm; you know there wasn’t that kind of same element of a bulk level of applications or interests from comparable parties, like we are now seeing, you know, with storage contracts in particular, or solar contracts. You know there are now lots and lots of projects that look the same and therefore there’s a need to treat people equally.

00:06:54 – Pete Aston
And at distribution Nikki, what sort of things have the distribution customers had to learn as well? Because I guess in the past distribution customers didn’t always think that there was a transmission network. They didn’t even need to know that there was a transmission network somewhere above the GSP, but how has that changed over the last couple of years?

00:07:12 – Nikki Pillinger
So that’s changed hugely actually. Certainly, when I started doing this, going through what we called the statement of works process was quite a standard thing that you did. The DNO would send off an application to National Grid. National Grid would come back and say, yeah, that’s okay, you can go ahead and you can connect.

Over the last three or four years or so we’ve had very different responses. So, distribution customers have had to get used to not only much longer connection timescales but also a very different cost impact. So if you have a transmission impact assessment that comes back with the new Super Grid transformer something we’ve spoken about quite a lot, the distribution customer may have to pay for either all or part of that, depending on how many people are in that Mod App queue and how many people stay in that Mod App queue.

Also, securities and liabilities have got exponentially higher, so projects would have ordinarily just had sort of wider liabilities and securities that would kick in at their trigger date, whereas now they’ve got quite a lot of attributable securities and liabilities which can be really, really high. You know these can run up into the millions of pounds. So very much a step change in terms of quite early liabilities, financial liabilities for projects.

00:08:35 – Pete Aston
Yeah, thanks, Nikki. Yeah, and I don’t think it’s just developers that have had to learn, because I think, from a distribution point of view, lots more people, employees in the distribution companies have had to learn about transmission processes. So, previously, if you were an 11kV connection engineer, you probably wouldn’t have had to talk to any of your direct customers about transmission system. But now, as an 11kV planner, you’re briefing your own customers who are installing, you know, two, three, four megawatt generation schemes and you’re briefing them around the project progression process.
So, there’s been a lot of learning within the distribution networks and lots of learning within the transmission companies as well, because they’re now having to learn a lot more about the distribution system because the distribution customers are impacting on them.

So, yeah, I think there’s just been a whole lot of learning across the industry and it’s, I guess, change always feels a little bit haphazard at times, and it’s probably been so, but I feel like people are starting to get to a place where everyone knows reasonably well what the deal is at the moment. I don’t know if you agree?

00:09:40 – Nikki Pillinger
There’s a lot of stuff that’s still not actually written down, like with the Super Grid Transformer charging. There is a working group looking at that at the moment, but it’s by no means uniform as to how those charges are administered or how they are securitised or treated by the DNOs.

00:10:02 – Catherine Cleary
Because I suppose there’s been a level of caution, possibly almost a bit of a cautionary learning exercise from generation, and how quickly it did snowball Pete, you know, in terms of every type of generation, you know, really, from a megawatt upwards being classed as significant, and that learning or that caution now possibly being applied to demand. You know, which is perhaps an overreaction.

But I suppose that the concern from a DNO’s perspective, is I don’t want to repeat the potential errors of the past in terms of sort of, you know, waving lots of things through and then turning around and realizing we have a big transmission demand constraint and so perhaps sort of seeing people being more cautious from a demand perspective as well.

00:10:40 – Pete Aston
Hmm, interesting. I can remember a senior manager where I used to work when the solar rush first started, who said it’s okay, this is just a bump, we’ll go back to normal next year. And, of course, the bump turned into an enormous great step change that has continued to get bigger for the last 10 or so years. So, yeah, I think sometimes the industry has been guilty of over-optimistic thinking and then potentially, on the other flip side, being overly pessimistic as well.
So, moving on from just that sort of growth in the queue, let’s just pick up on Significant Code Review. So, Catherine, I don’t know if you could very briefly outline what the Significant Code Review was. So it came into force April 2023?

00:11:29 – Catherine Cleary
2023, which seems like a really long time ago, but it’s actually only a year and a half ago and I think we thought this would be the big news story, didn’t we? That we’d all be talking about this for ages, and then other things have come and supplanted it. But effectively, that looked at changing the charging boundaries for customers connecting to the DNOs networks of distribution customers, it removed reinforcement charges for demand customers, so you know, that was sold as being quite a big, positive story as making the charging arrangements shallower for distribution customers.

For generation schemes at distribution, it just limited your reinforcement charges, didn’t it? So, effectively, to the kind of voltage level you were connecting, And it also explicitly put an onus on the DNOs to consider ANM solutions so they couldn’t just sort of say, oh no, you know, we’re just going to do this bit of reinforcement. They had to consider flexible solutions and set out some more kind of standardized terminology, I suppose, that we use and actually standardized methodology for assessing constraint as a result of ANM – which is the dreaded spreadsheet Pete!

00:12:41 – Pete Aston
Yes, I think we have to mention the dreaded DCP 404 spreadsheets. Those of you who are familiar with this will also find it terrible. I think the outcome of that was trying to implement something that was common across all the DNOs for assessing curtailment, and it feels like they just went to the lowest common denominator of what could be achieved…

00:12:57 – Catherine Cleary
And that was really quite low!

00:12: 59 – Pete Aston
… in a really short time scale and it came out with something that was really quite awful, very clunky assumptions just couldn’t take into account more than one constraint point and all sorts of things like this. So, we have been lumped with that over the last 18 months, but I believe that there are some conversations now going on with different DNOs trying to improve on this.

00:13:22 – Catherine Cleary
Yeah, I was going to say that I think possibly all the things we’re going to talk about, the SCR is perhaps the thing where the impact of it, a year and a half on, is perhaps most different to what we would have envisaged, in that I think we probably thought there was going to need to be a or there might be a kind of significant shift in people’s behaviour and quite a lot of trying to sort of game the system around SCR charging. We haven’t really seen that, you know, partly because I think actually there’s probably a reasonable amount of firm pushback from a DNO against trying to kind of game the system. So that would be maybe, you know, applying to try and get a lower voltage point of connection and then, you know, later coming back and increasing your capacity and so on.
I guess the complexity of things like the transmission impacts that Nikki’s talked about and stuff has meant that gaming isn’t really a pragmatic way to go. You know the applicant would potentially be disadvantaged anyway because they might have their transmission impact assessment in two clumps or something like that. So, I think there’s been less of that kind of potential downside.

And the upside… I think it is worth saying that because before that point there was a really piecemeal approach to whether or not ANM could be considered, and I guess it’s not that many years ago where you might have applied – quite a lot of the network operators and they just simply said, no, I’m sorry, we can’t offer you an ANM connection, we haven’t rolled out ANM in that zone yet.

So, I think that’s probably quite a big win that we’ve maybe just taken for granted now is that actually ANM is basically offered across the board, pretty much across the board. I might touch on ENW at some point, but it is coming for a number of reasons, the SCR being the first, and then probably tech limits and things which we’ll come on to have just kind of added to that emphasis.

And I think from the awfulness of the standardized spreadsheet has, perhaps, come maybe that’s given even more weight to the fact that this needed more industry attention. You know what is the best way for a DNO to share data regarding potential future curtailment?
And Nikki, I mean, I think you’ve probably seen more than me, but you know it does feel like now we are getting progress from DNOs in publishing better methodologies, sharing far more data publicly.

00:15:31 – Nikki Pillinger
Yes, very much so. As you said, it’s been quite piecemeal with the DNOs Some of the southern DNOs, they had the renewables revolution sort of first, so they’ve almost had to deal with that sort of active network management capability before some of the other DNOs. However, we are seeing much more transparency in data, because ANM is such a big risk and it is so uncertain, people want as good evidence as they can do to show what that might actually turn out like for their project. So most DNOs now have something called an open data portal or something of that name. Some of the DNOs are doing their own curtailment reports and offering their own curtailment reports, whereas some other DNOs the onus is still on developers to ask them for the data and get their own curtailment report. Quite a lot of the time people will do their own curtailment reports anyway, but the DNOs are making much more of that network data available.

00:16:31 – Catherine Cleary
And those open data portals are actually quite good, aren’t they? I mean, most of them, I think, have been developed by the same software provider, so they look quite similar and it’s getting easier to kind of find your way around them and find some really quite useful data. I was, I was, pretty overjoyed to discover on UKPN’s that actually they publish a full list of all of their EHV outage works, both like recent and planned. They don’t sadly, actually name the circuit, something that is publicly accessible, I mean one step at a time!

00:17:00 – Nikki Pillinger
They do. UKPN, have been very good actually at engaging with customers. They’ve done a great many workshop sessions, some of which Roadnight Taylor and I have been involved in, in terms of what customers need and what data they can and should make accessible to customers to do their own curtailment assessments. They’re also going to have a self-curtailment tool soon which will be really interesting to see. I think that’s potentially coming out at the end of the year.

00:17:24 – Pete Aston

I agree with you, Catherine, that we thought probably the charging element was going to be the big one and maybe either customers or DNOs would do some gaming. But actually it’s probably been the ANM bit that’s probably been more significant. But actually, having said that, I’ve been working with a few clients who’ve definitely benefited from SCR charging rules, especially some demand customers who had had, like, a previous offer in the year before SCR was introduced. Then the new offer they get is significantly cheaper with SCR coming in. So, there’s definitely been some improvements for some customers in the charging side of things, which is good.

But I think the other thing that’s worth picking up and this what Nikki was mentioning a bit earlier is that transmission charges aren’t impacted by SCR at all and we are seeing now more transmission related charges being put on to distribution customers through, for example, supergrid transformer reinforcements. I mean, that’s the main issue of charging from the transmission point of view and so that can be very significant, and the SCR didn’t address that at all, it could have done, but sort of chose not to kicked into the long grass.

00:18:33 Catherine Cleary

Yeah, bit of a missed opportunity.

00:18:35 –  Pete Aston
Yeah, okay, let’s move on from SCR, so we’ll pick up on now on National Grid ESO’s Five Step Plan.

So, as the transmission queue is growing, rapidly growing, in Feb 2023, National Grid ESO issued the now famous, maybe infamous, five-step plan. So, Catherine, if you could very briefly sort of touch on some of the points – I’m not going to ask you to list all five absolutely without looking but just generally speaking.

00:19:05 – Catherine Cleary
Well, we did think could we name the five points of the five-point plan? I think, looking retrospectively, it’s not perhaps… a lot of them have merged… I think maybe it’s a two-and-a-half-point plan!

So, there was a TEC amnesty initially which was perhaps the first sort of public statement of you know. look, we need to start trying to clear out the queue.

00:19:28 – Pete Aston
Which wasn’t spectacularly successful?

00:19:29 – Catherine Cleary
Yeah, I was going to say I think the ESO would claim that was successful, but in the grand scheme of things, I mean, they got rid of eight gigawatts in the end. You know, which in the old days would have been quite impressive on a sort of you know, 150-gigawatt queue. But in the kind of current climate, it doesn’t really make any difference. So, a bit of a kind of political move as opposed to anything which had any impact.

The revised CPAs – so this was kind of part of what triggered what was then termed the Transmission Works Review – and that that had the potential to be really significant and sort of still does. I mean, the big one was the idea that we would set batteries to kind of a grid neutral position when the ESO and TOs did their modelling, and also the idea that the CPAs should include attrition rates, so we shouldn’t assume that everyone who’s in the queue will go ahead and build, and they were quite ambitious. So, the proposed CPAs assumed that two-thirds of projects wouldn’t go ahead and build, so you got rid of two-thirds of the queue.

00:20:32 – Pete Aston
That is significant, isn’t it?

00:20:34 – Catherine Cleary
It is really significant compared to the old way of modelling. I think there was a slight caveat in that it was 50% in the local area to where the generation was connecting, but two-thirds everywhere else. I know this because I did go back and look at some of the slides. When this was first proposed, the proposal was that it would include embedded generation as well. So, we would knock out two-thirds of the embedded queues you know, which would have had a really big impact on you know, are we triggering new SGTs and things like that? And I think you know that was obviously the start of a conversation but not the end of it.
So, there were kind of a couple of things weren’t there? Firstly, the Scottish TOs pushed back quite a lot on those CPAs, initially didn’t adopt them. There was a long, protracted conversation about what the right CPAs were and as a result, we had this sort of situation where the Transmission Works Review ran ahead in England but behind in Scotland by quite a long way. And I think it’s worth saying that the final CPAs that have been used for the Transmission Works Review have never been published. So, although we know what the sort of starting point was, I think it was clear that there was an element of pushback as to whether you know, is that two-thirds acceptable?

And also, you know, from a technical perspective, how is that actually administered? Are we taking all of the generators and knocking away two-thirds of their TEC? Are we knocking away two-thirds of the generators entirely? Because that’s a very, you know you’ve got one to two kV circuit in Scotland and you’ve got, you know, two people who are connecting to T onto it. You know it makes a big difference if you’re taking one of them away or if you’re just halving their capacities. I think the granularity of that was a big challenge and it’s still going. That’s really important. The Transmission Works Review hasn’t completed.

So, although the five-point plan feels like a long time ago, actually we haven’t got to the conclusion of two of its really main points yet,

00:22:17 – Nikki Pillinger
I also don’t think that did include embedded generation, or we at least haven’t been told that it has done.

00:22:25 – Catherine Cleary
No, it was meant to though originally, yeah.

00:22:28 – Nikki Pillinger
We thought it might make a difference to the amount of super grid transformers that were being triggered, because now that two-step offer process has concluded, pretty much the result of that for most people is you need a new GSP and we don’t know where it’s going to go.

00:22:44 – Catherine Cleary
Yes, well, of course, because the Transmission Works Review triggered the two-step offer process, didn’t it? You know that was, that was basically NGET, actually, as a TO saying, you know, hang on, if we, if we need to go back through and do this entire Transition Works Review process, you sort of need to give us a bit of time off from doing normal connection offers. Is that one of your next points, Pete?

00:23:04 – Pete Aston
Yeah, I was going to say I think my note here says that kicked off in April 2023 – the two-step offer process – and was, I think, was due to end in February this year but got extended by a further three months, didn’t it? To end of May this year. So, there was just over a year’s worth of sort of two-step offer review process where customers would get this sort of holding first-step offer and then a final two-step offer, and during like the second half of last year particularly there was quite a lot of hope to start with, wasn’t there that these revised CPAs and so on – this was going to be it. People were going to get offers with significantly reduced connection dates.

00:23:48 – Catherine Cleary
Yeah, exactly. Well, I think we shared a bit of optimism there that effectively those step one offers would be a kind of worst case perspective and that once you did start to take into account really significant changes in CPAs, taking out two thirds of the queue, that would remove the need for Transition Works and so the Transition Works Review would cull the long list of transmission reinforcements proposed. And I think, with the benefit of hindsight, actually it was probably, I would say probably after about the first six months of that what ended up being a like 15-month period, the warning signs were probably in the volume of applications.

You know that that two step offer process didn’t really deter people from applying. They could accept a step one offer with no liabilities, you know. So, there was almost kind of no skin in the game. So, the queue kept growing at about sort of 25 to 30 gigawatts every month, every couple of months, I think. And so I suppose what we did was we grew the queue in that interim two-step offer process far more than we stripped out reinforcement works. So actually, the idea of saying, well, we’re going to give everyone worst case offers based on the terrible kind of list of transmission reinforcement projects that we’d identified already in April 2023. And that’s clearly not going to get any worse. Actually, that wasn’t great.

00:25:17 – Pete Aston
Yeah, and I think as well, that everyone was getting pretty similar step one offers, but actually the reality was there was no study work or any assessment really done for those step one offers, and quite a few offers got significantly worse after getting the step two offer back, didn’t they?

00:25:33 – Nikki Pillinger
Yeah, definitely, a lot of them have just been. ‘You need a new GSP’ and we don’t know where this is going to go and we hope that Connections Reform is going to solve this. And a lot of distribution customers haven’t actually heard formally…

00:25:48 – Catherine Cleary
I was about to say distribution customers are lagging behind this.

00:25:52 – Nikki Pillinger
None…yeah, about what their result is.

00:25:55 – Pete Aston 
Yeah, because the two-step offers included project progressions as well, didn’t they? But I guess if the DNOs didn’t get their project progression step two offer until May of this year, some of them are still trying to work through that and reissue variations to customers

00:26:16 Catherine Cleary
Yeah, and some of them even retracted. Do you remember they were withdrawn by the ESO. So, you know, that was over some of the concerns around some of the technical assumptions. So, yeah, definitely like a long, long lag. I think that point about the fact that the reason that the step two offers didn’t improve people’s connection dates is, that they were, he step one offer was based on what everyone had assumed was a worst case scenario back in April 2023, as a kind of fixed snapshot in time, even if you applied nine months after that, as you say, Pete. No one was doing any more study work and at that point, actually, you know, another 200, 300 kilowatts had joined the queue. So, it was no longer remotely plausible that you were still going to get that step one date and even if you took out, you know, two-thirds of the queue

00:27:09 – Pete Aston
I mean effectively we’ve all been looking for a saviour to resolve the queue, but it keeps being a different saviour than the one we thought it was going to be.

00:27:17 – Catherine Cleary
That’s also this kind of element of time, you know. So, if you do something which is quite radical and it’s going to have a big impact, but it takes a really long time to implement, the queue carries on growing in the meantime, so that in itself can be a bit self-defeating.

00:28:01 – Pete Aston
So what else was there in the five-point plan? I think there was something around non-firm connections for storage wasn’t there to try and accelerate some storage connections? Has that really happened or has that got all caught up in the whole step two offer issues that we were just talking about?

00:28:17 – Catherine Cleary
So, the ESO would absolutely say it has happened, and it has happened. There are a small number of storage projects which got accelerated offers, so there were a few winners. But I think it was 10 gigawatts worth of projects, which might have been about 20 individual projects. That was batch one. So, in theory this work is still ongoing. I think in practice perhaps the industry’s lost a bit of confidence that it’s going to really kind of happen this side of Connections Reform, and therefore it’ll probably get kind of rolled up in some of the Connections Reform gate one, gate two discussions of next year.

So that one again, I think, so non-firm offers for battery storage, which were basically saying you can ask for an earlier non-firm connection date once your basic kind of core enabling works are done, so if there’s a substation, there’s a bay that you’re connecting into, but if you know you don’t have to wait for the wider reinforcement works to be done, or your enabling works which are non-critical. So, you know, if you had enabling work which was a circuit upgrade. So, that could have impacted lots of people. But actually, you know, it’s basically been sort of sorted through in tranches and only the first tranche, which came out a while ago now, I think, sort of around December last year, January this year, so about nine months ago. So, it has been radio silence on that one for a while.

00:29:36 – Pete Aston
And then sort of rolled up into the five-point plan were queue management milestones?

00:29: 40 – Catherine Cleary
Yeah, sort of working in parallel.

00:29:44 –  Pete Aston
It felt like it was going at the same time anyway!

00:29:46 – Catherine Cleary
Yeah, going at the same time, but perhaps a slightly sort of distinct process, because that was following the CUSC Mod process, you know, whereas the five-point plan initiatives were a bit more things within the ESO’s control, without going through a CUSC Mod

00:30:02 – Pete Aston
I mean so they, they are now implemented and they’re in offers and so on. But I guess with the offers I’ve seen everyone’s sort of a bit like well, we’re still waiting to see what’s going to happen with Connections Reform, so maybe these milestones that I’ve got aren’t so important at the moment.

00:30:16 – Catherine Cleary
And the milestones were backwards looking rather than forwards looking. You know, which has been the whole discussion point really ever since they were implemented is do they actually have any impact soon enough? Because if everyone’s got quite late connection dates and you don’t have any milestones, you know, but before you get to kind of five years before your connection date, then actually you’ve got sort of two-thirds of the queue who didn’t have any milestones until you got to, you know, kind of like the late 2020s or 2030s.

So right from day one, as soon as they were implemented, there was quite a lot of scepticism as to whether they would have any impact soon enough. But they did, because I guess the penalty of missing a milestone under that CUSC Mod is now very severe. You know it is a termination, a potentially automatic termination, if you miss one of the first three milestones.

So that in itself did have a bit of an impact, because the ESO said we’re going to give everyone a window to Mod App once. if you want to change those milestones, if you think that you’re at risk, and so that probably did generate a bit of kind of thought and interest and also generated a fair few numbers of mod apps for the ESO to deal with. So, I guess that that’s quite an important point because that that window for those mod apps being submitted only closed earlier this summer, didn’t it? That was that was May 2024 as well.

00:31:27 – Pete Aston
Yeah, and then the other thing on the ESO’s five point, there were a few tactical solutions sort of knocking around along with the five-point plan, which I think have probably mostly got tied up with Connections Reform. So there was the implementation of a letter of authority for making an application.

00:31:49 – Catherine Cleary
Yeah, so that’s been implemented.

But it’s kind of letter of authority., o you need a letter of authority now to submit a transmission application, so that’s good. But it’s still kind of letter of authority version one, as the ESO would call it. So, it’s not particularly sophisticated in the sense that there’s not necessarily to go alongside that kind of here’s my land. There isn’t the same concept of a kind of material change at transmission, so actually at the moment there’s not very much to bind you to that land. You know, what happens if you apply with one land parcel and then move the project. So, what happens if you apply with the same land parcel as someone else, and so kind of checking for duplicates.

All of that has been bundled into what was going to be sort of LOA version 2, which is now part of Connections Reform

00:32:30 – Pete Aston
And was there something then around, also sort of technology change, allowable changes for different technology types, so can you apply as a solar and then change to a wind farm or something? Has anything like that come out yet?

00:32:44 – Catherine Cleary
Yeah, I think soon the ESOs – they had a kind of snake diagram that people probably seen at conferences, which was tactical initiatives that were going to be implemented kind of prior to connections reform. These were kind of like smaller, bite sized chunks of things they could change more easily, and one of those was basically publishing a policy paper on what was a material change or allowable change, and the other was regarding like new applications. So, I think those have been split out for a while, but basically saying, what are you allowed to do as part of a Mod App and what do you have to submit a brand new application for. As I understand, neither of those papers have been published and although there is quite a lot of work going on or had been quite a lot of work going on, Laura Henry had led lots of that work at the ESO. So, I think now it sounds like that is effectively going to get wrapped into Connections Reform.

00:33:39 – Pete Aston
Yeah, ok, brilliant. So that was the five-point plan which was published February 2023. I think it was a few months after the publication of the ESO’s five point plan that the ENA, either coordinated or they just thought they had to do on themselves, issued their own three-step plan, one of which was effectively sort of transmission distribution interface, which was effectively Technical Limits.

So, Nikki, I don’t know if you want to briefly talk us through sort of the Tech Limits rollout, maybe very how you know, maybe very briefly what it is, how it’s been going.

00:34:18- Nikki Pillinger
So, Tech Limits was a scheme that effectively, the idea of it was to allow people who were ready to connect to connect to the distribution system. This was a little bit of a misnomer, in that anyone that had a 2028 or 2030 connection date would not be really in any way ready to connect, because that wouldn’t have been a particularly reasonable expectation. So initially it was, you know, people who had got planning, people who had got land, people who had gone through some sort of engineering design, which, of course, you would not have done if you couldn’t connect your project for several years. So, what Technical Limits turned into was a scheme that people could apply to the DNO for an earlier but constrained connection. This was enabled by the DNO applying to National Grid and saying what capacity is unconnected and sort of unutilized as yet at this GSP. So Technical Limits has been administered by all of the DNOs it’s been administered slightly differently by all of the DNOs.

ENWL has a very different approach to the curtailment, which is a sort of a shared curtailment which they may well be re-evaluating due to that being a very risky tactic for developers because essentially, you’ve got unlimited potential curtailment.

So Technical Limits has sort of benefited quite a few generators. It does, however, add a massive element of risk into a project, in that you don’t know how many projects ahead of you are going to connect and you may already have ANM on a project anyway. So Technical Limits, it will last until the transmission reinforcement is completed. So, say you have transmission reinforcement that’s due to be completed in 2032. When you connect you will have that curtailment until 2032 when the transmission reinforcement is completed, and then you will have your sort of connection as that would have looked like beforehand.

So, it’s a really positive scheme for some projects. Like I said, quite a large element of risk, especially for projects that are much lower down the queue, because you don’t know how many people ahead of you are going to connect and there’s a lot more sort of risks in terms of network configuration, network behaviour at that point.

But it is positive for some projects.

00:36:50 – Catherine Cleary
I know that when the first sort of Technical Limits offers came out and obviously, we talked about the fact that things like Technical Limits just allows you to connect earlier. It doesn’t remove the need for you to pay for things like connection assets, SGT, new SGTs and things. A lot of people said, well, can I just have my constrained connection forever? And that sort of seems to have caused a lot of consternation, with people saying, oh, that wasn’t what technical limits was designed for. Have we got to an answer on that yet? Can people just opt for a constrained connection forever where they don’t think it makes any economic sense to build a new GSP or something like that?

00:37:23 – Nikki Pillinger
That question is asked on, I think, almost every Technical Limits webinar that I go on to and unfortunately there hasn’t been an answer for it yet. The thing with Tech Limits was that it was, the idea of it was, that it could be administered quite quickly and to all GSPs. In reality, Technical Limits doesn’t work for quite a few GSPs across the country. It works quite well where you’ve just got a thermal constraint because you can manage that via ANM. It doesn’t work where you have a fault level constraint particularly. In fact, I haven’t seen any technical limits offers for sites with fault level constraints yet.
They may have been offered out, but I haven’t seen any to sort of know how that fault level constraint is being dealt with under technical limits. It’s very difficult with infrastructure sites as well.

00:38:00 – Pete Aston
I think the way they were doing the fault level ones, Nikki, was they were going back to doing a re-evaluation of the fault level at the site and going is there anyone we can squeeze in up to the fault level headroom? And if they could squeeze someone into the fault level headroom then they put them on the ANM, the thermal issues, but anyone who definitely was outside of the sort of fault level rating. I think it was just you’ve just got to wait for the reinforcement works.

00:38:44 – Nikki Pillinger
Yeah, so challenging on sites with fault level issues, both at distribution and transmission. Also, just as sort of a word of warning, there are some, I’ve seen some DNO offers that have said you can have an earlier connection date. But those DNO offers haven’t actually incorporated any works the DNO has to do, or any sort of costs for anything that the DNO has to do. So be very, very wary of Technical Limits offers, because sometimes they’re absolutely not telling you the whole story.

00:39:15 – Pete Aston
And of course, our old friend the, the DCP 404 curtailment spreadsheet rears its ugly head again. Because that’s how most of the technical limits, sort of predicted curtailment was being calculated and passed out to customers as well, which certainly led for some very or potentially high levels of curtailment, or at least very unrealistic levels, being presented to customers.

So anyway, that was Technical Limits. So that’s the thing it’s going on. Potentially for some customers it will prove to be proved to be useful. So then, under the three-step plan, there was a couple of other bits.

There was some tactical solutions for batteries…

00:39:59 Catherine Cleary
Do you know what they were Pete?

00:40:00 – Pete Aston
I do actually because I did a little bit of a review on these! So, one of them was effectively mandating that storage connections will be non-firm. So, all the DNOs now will issue every battery offer as non-firm and you get some really interesting interpretations of what that means.

00:40:25 – Catherine Cleary
So not P26 compliant would sort of be one extreme definition, and presumably ANM would be the other?

00:40:34 – Pete Aston
Well, I think the way that they’ve tend to have interpreted non-firm is any, you are basically able to be tripped and will be tripped out for any outage on the system so,

00:40:46 – Catherine Cleary
Which is really what we would have referred to, a single circuit risk, which 99.9 percent of those connection offers would have been in the first place?

00:40:52 – Pete Aston
But what I’ve seen, Catherine, has come out like, so for one battery connection I was involved with, it was connected, effectively a T off or a loop in connection to a 132 kV circuit.

So obviously for loss of the circuit they’re connected to, and it was just a radial feed to a transformer. So, you lose that circuit, you lose the battery system. I don’t think anyone would have batted an eyelid at that. But it was also going to be inter-tripped for an outage of the other circuit down to the BSP. So, you know that that was like sort of belt and braces. Well, we’re definitely going to trip you off, not at some point in the future we might need to trip you off for this outage if we don’t have sufficient capacity or something like that. It was just we’re just going to trip you off because you can’t. You must be non-firm and therefore trip you off for everything.

And then I’ve seen batteries coming in just as ANM, without any caveats. It without any caveats, it’s just you will have ANM for anything that we feel that we want to give you ANM for. So, I think it’s been applied quite broadly. I think that one it’s probably a good thing but maybe just needs some careful consideration of what the offers look like when they come out.
And then the other one was putting some commentary around P2 and basically applying diversity to non-flexible battery customers’ schemes that had already been accepted. So, there’s a whole queue in the distribution systems of battery schemes that don’t have these non-firm arrangements, so what do you do with them? So, it was applying a level of diversity to those not particularly high levels of diversity.

00:42:30 – Catherine Cleary
So not a huge impact probably.

00:42: 34 – Pete Aston
So not going to help that much. I don’t think was my initial thoughts.

00:42:36 – Catherine Cleary
And the sort of third kind of problem area I would have said for batteries at distribution from a kind of ENA standards perspective was the P28 issues for batteries and you know some DNOs being very concerned about instantaneous step changes or kind of coincident step changes from batteries. And the ENA three-step plan didn’t talk about that. I don’t think, Pete?

00:42:55 – Pete Aston
No, no, not at all, but I do think if there would be some reasonable weight to say if you have to apply diversity for demand security, like on a P2 basis for just considering load, apply the same level of diversity at the very least when considering P28 for step change.

00:43:14 – Catherine Cleary
Yeah

00:43:15 – Pete Aston
But I don’t know anyone that’s actually picked that up yet.

00:43:17 – Catherine Cleary
Yeah, I’ve still seen a few offers coming out from some of the northern DNOs, with some quite kind of well, either pessimistic or perhaps just very difficult to interpret P28 restrictions on batteries. So, I think that’s definitely still an issue.

00:43:32 – Pete Aston
Yeah, absolutely. So yeah, three step plan has definitely had its own impact as well.
So, moving on, we are very quickly running out of time. Connections Reform. Now we’ve already said a lot about Connections Reform on webinars and podcasts, so we’re not going to say very much, apart from maybe to very quickly sketch out the timeline, the history.

00:43:55 – Catherine Cleary
Yeah, I suppose because Connections Reform actually did run basically in parallel with some of these things. So, we had Connections Reform, there was a kind of industry consultation on the ideas behind Connections Reform. It didn’t really set out any kind of clear straw man proposals, but it ended in a document which the ESO called their final recommendations. And I think in some ways the reason for pulling this out, Pete, I think, is that perhaps that consultation got a lot more wider interest perhaps than now Connections Reform is in the kind of Code Mods territory, so the CUSC Mods and kind of code, working panels. It feels like a very sort of transmission, geeky kind of legally piece of work, whereas the kind of initial sort of consultation was more of a kind of what do you think about following ideas.

But it’s changed a lot, hasn’t it so the kind of actual technical proposals within Connections Reform are really quite radically different to what was outlined in in the ESO’s final recommendations paper. And so, yeah, I think that’s probably just a nod to the fact that over in the course of about, you know, nine months between November 2023 and when that final recommendations paper came out, and when you know we’ve just this summer had that consultation on the current Code Mods.

There’s a really big difference in what’s being proposed, and I think you know, given the number of the work groups, have had back the consultation responses and they’ve had about 60 to 80 responses for each of the code modifications. So, CMP 434 and 435. I guess, given the number of those and the ESO’s comments already we’re expecting changes again.

So, Connections Reform is basically just constantly in flight.

00:45:36 – Pete Aston
Yeah, and I think it’s also worth saying Connections Reform was due to be rolled out January 2025.
That’s now being pushed back to what, later on in the spring.

00:45:47 – Catherine Cleary
Yeah, I think we’re waiting for the public announcement on that, but that that seems to be the kind of indications that have gone to the working group.

00:45:55 – Pete Aston
And I think it’s also worth picking up on that that already there’s now lots of talk around sort of additions to Connections Reform or further strengthening of it, required because there was a request for information. Wasn’t there done by the, the ESO along the lines of if you were, if we were to roll out this process, you know what, what would sort of impact be on your project, you know, would you be able to meet the gate two milestones that we’re proposing, or not?

00:46:25 – Catherine Cleary
I guess it was specifically really so CMP 435, which is looking at applying it retrospectively to the queue. It was specifically trying to say well, if we do apply this retrospectively to the queue, how much of the existing queue either meets gate two now or is in a position to meet gate two? And the answer is that the vast majority of the queue that responded to that RFI said that they would meet gate two by the time that this was implemented next year. So, I suppose that in itself is a slightly worrying sign that Connections Reform isn’t going to have very much impact.

There are a couple of ways to look at that, because it’s worth saying that, whilst the majority of transmission projects responded, only I mean, I think it’s less than a quarter of affected distribution projects responded to that RFI, so it was not necessarily particularly well publicised by all parties, and so you could say well, actually, maybe the people who are most likely to proceed are the ones that responded. So, there are a couple of ways of reading that, I think. But yes, that result has been taken to the kind of regulatory group that oversees Connections Reform, which includes Government and Ofgem. I think that they have both instructed the ESO to go ahead and look at further measures of what could be done to try and reduce that queue. You know, looking in technology limits or kind of further financial measures, and we’ve touched on that in another podcast that we’ve released recently as well, so that’s probably, you know, sort of what to look out for next.

00:47:48 – Pete Aston
Okay, and then I think that’s probably all we want to say really, on Connections Reform. I guess now we’re just drawing to a close on this sort of two-year review. Some of the things coming up, looks like there’s likely to be more intervention around, maybe things like technology and location within the country, around that sort of strategic spatial energy plan, SSEP – is that right? Have I got the right acronym?

00:48:14 – Catherine Cleary
Yeah, definitely the right acronym.

00:48:16 – Pete Aston
Okay. So yeah, lots more sort of government-level intervention there. It’s going to be interesting to see how that pans out and how that interacts with the Connections Reform and so on.

I guess, associated with Connections Reform, there’s more work to come on bay allocation and bay sharing. I don’t know if you’ve got any thoughts around that?

00:48:34 – Catherine Cleary
Yeah, again that we probably covered that recently in Grid News and Views But there is a draft paper that’s quite positive on bay sharing, so just looking forward to publication of that and beginning to implement that from the ESO.

00:48:46 – Pete Aston
Yeah, then there’s just sort of a few other things ticking around that’s probably worth highlighting.
There’s some decisions for Eclipse, who are looking to have the first independent Transmission Operator license awarded. They’ve sort of been looking to apply for transmission licenses. It’ll be really interesting to see where Ofgem takes that and whether Eclipse are able to get that.

00:49:09 – Catherine Cleary
Yeah, I mean, I think you know, given all of the resource constraints, it would be hard to argue why appointing another TO is a bad thing. But yeah, so watching that with interest.

00:49:22 – Pete Aston
Then I think there’s probably issues I think it was mentioned a little bit earlier by you, Nikki, just around the impact on demand customers with all of the network restrictions at the moment. So demand customers have been caught up with a lot of these really long connection dates. So we’ve seen customers in West London and other places impacted by not able to connect more than one megawatt or having some other long connection dates and so on. So it’ll be really interesting to see what happens with those sort of demand connections. Because I think at the moment demand customers as a collective aren’t aware of these transmission issues or aren’t as aware of transmission issues as generation customers.

00:50:03 – Catherine Cleary
Yeah, and are potentially sort of fairly fundamentally underrepresented in a lot of the forums where these changes are being discussed.

00:50:11 – Pete Aston
Yeah. Then there’s various sort of regional energy strategies coming forward, further work to go on SGT charging – we’ll keep banging the drum on that one, I’m sure and then the sort of new government Labour governments overarching clean power by 2030 drive how they want to try and push that forward. So it’ll be interesting to see what comes out of that.

00:50:29 – Catherine Cleary
Yeah, and I think the only last point for me was just that actually we are coming up to that, although it seems like a long way away. 2028 is the start of things like the next transmission regulatory framework, so RiiOT3 and we’ve got ED3 coming up after that, so DNOs and TOs putting together their kind of spend profiles and their plans for reinforcement.

50:55 – Pete Aston
So I think that probably concludes our run through the last couple of years. It’s been a really, really, really, really busy couple of years. Lots of significant changes have happened that are setting the groundwork for forthcoming years. Be interesting to see what happens in the rest of 2024 and 2025. But we hope this has been useful. It’s been good for us to go back over the last couple of years and see what’s happened.

Just let us know your comments at some point. If you want us to cover anything else on this podcast, please let us know and we’ll endeavour to do so, but for now, goodbye!