Podcast: Grid News and Views #14

00:00:22 – 00:00:39 – Kyle Murchie

Hello and welcome to another Roadnight Taylor Connectology® podcast. I’m Kyle Murchie and today I’m joined with me I’ve got Philip Bale, Catherine Cleary and Alex Ikonic but not here as a guest this time, here as a full blown Connectologist®!

00:00:39 – 00:00:40 – Catherine Cleary

Yeah, welcome Alex.

00:00:40 – 00:00:42 – Alex Ikonic

Thanks everyone, very happy to be here.

00:00:42 – 00:1:26 – Kyle Murchie

So, it’s been a while since we’ve done a Grid News and Views. I think Pete and I actually did one probably about a month ago now, but we did try to cover quite a lot in that session and since then, there’s been lots more to talk about and we’ve also had just lots of things that we didn’t quite get to at that Grid News and Views.

So today we’re going to try and delve into lots of key points. There’ll be Connections Reform elements of course but there’s also lots of other things going on, lots of Code Mods as well that we want to get into some detail on. So don’t know who wants to open up. What’s the first thing on everyone’s mind. Maybe we start off with Connection Reform type topics.

00:01:27 – 00:02:53 – Catherine Cleary

Yeah, I mean I suppose I’ll go first if you like with a few kind of quick updates. So, I suppose one of the things people to be aware of is in the Connections Reform space we’ve had an Ofgem publication in the last couple of weeks around how they’re going to handle disputes so how they would determine on disputes in the kind of Gate 2 process or the Connections Reform process.

There is a consultation element to it so it is a kind of minded two positions. It sets out their kind of sort of process. It actually closes in two days time so probably by the time this goes out it may well have closed. But I think the thing to flag there is that Ofgem have come out with quite a strong position really of saying we’re probably not going to get very involved.

So effectively, they said we’d only get involved in determining on a complaint relating to something like, for example, like a Gate 1 or a Gate 2 status if the complainant had, first of all, exhausted all other options, even going through arbitration or something like that. And secondly, if they could provide conclusive evidence of wrongdoing by a network operator or by NESO. And I think the burden of proof, therefore, is on the complainant.

So, I think one thing to flag there is that it’s kind of sending a signal, I think, to industry to say, well, Ofgem aren’t expecting to get involved in the weeds of, you know, has the process been followed correctly for this specific site, if it gets a Gate 1 offer or something?  And therefore, I think probably we need to be making sure that we’re all kind of cognizant and familiar with NESO’s own complaint process, because that’s going to be the main avenue.

00:02:53 – 00:02:55 – Kyle Murchie

Okay, so it’s more of a backstop sort of approach rather than being the…

00:02:55 – 00:03:21 – Catherine Cleary

Yeah, I mean, I think, to be honest, reading between the lines, you know, there’s almost, it almost appears like there’s no scenario where Ofgem would make a, determination because they basically said, you know, we’d expect you to go to kind of, you know, arbitration routes and so on.

But also, if you have done that, we’re not going to make any determination which is different from any arbitration determination. So, I think really what they’re saying is they needed a statement, and their statement is very much sort of saying, actually, we don’t really think this is our place.

00:03:21 – 00:03:38 – Alex Ikonic

And I think what’s important about that as well is they also said that even in the case where they did have to get involved, there’s not much that they could do to sort of fix it, just because of how quickly Gate 2 to whole queue needs to happen. And it’s not like they could sort of instruct NESO to put someone back in the queue.

00:03:38 – 00:03:52 – Philip Bale

And obviously everyone’s going to know roughly where they are in the queue if they’re going to get a Gate 2 offer, a Gate 1 offer starting December in terms of coming through, but a variety of different dates coming out from TOs, NESO and DNOs in terms of when people are actually going to find out when they’re going to find that information.

00:03:52 – 00:04:17 – Catherine Cleary

Yes. So, no later than the week commencing the 1st of December has now also been turned into the third week of December by one DNO. So Northern Power Grid had recently said they think that’s going to be a couple of weeks later for their DNO related customers. So, I think, yeah, quite a key one to track, for DNO customers, are you expecting that notification to come directly through to you or is the DNO going to do some level of triaging and pass through, in which case it might be a couple of weeks later.

00:04:16 – 00:04:30 – Philip Bale

And our understanding is that customers will only know if they get a Gate 2 offer or a Gate 1 offer. Not to know if they’re in phase one or phase two of Gate 2, for DNOs, which I think is going to be challenging for some projects.

00:04:30 – 00:04:33 – Catherine Cleary

Yeah, it’s quite different really to what NESO said for direct transmission customers, isn’t it?

00:04:22 – 00:04:34 – Philip Bale

They said that they will tell them …

00:04:34 – 00:04:36 – Alex Ikonic

Which phase they’re in.

00:04:37 – 00:04:38 – Philip Bale

Which is why I think what’s needed.

00:04:38 – 00:04:39 – Catherine Cleary

Yeah absolutely.

00:04:39 – 00:05:34 – Kyle Murchie

I think interestingly on that we were involved in a session earlier this week with NESO and some of our colleagues from the industry and things like that are at least getting picked up and discussed.

So, you know, even when obviously we’re recording this now, but also when this comes out, I think there will be quite a bit of traction between now and that first couple of weeks in December with some of those things changing and potentially a little bit more clarification.

Also talk about information being shared which would be really pretty key. We talked about this a bit earlier in another podcast but, information is going to be really key. If you get an offer out and you’ve only got what’s sitting in front of you, that’s not all that helpful if you can’t actually even just sense check against publicly available information or information that would be in the open data portal. So yeah, watch this space. We’re certainly pushing for more and more of that.

00:05:34 – 00:06:03 – Catherine Cleary

And I think just, we like highlighting good practise, but I think a shout out to UKPN who’s done an amazing job in terms of some of the Gate 2 information is already published on their portal, which sort of splits not by project but split down by GSP and by technology type. How many projects, solar under a particular GSP are going through into the kind of Gate 2 queue. How many are going into the Gate 1 queue, how many didn’t apply at all and how many are sort of out of scope. So that kind of really clear demarcation is helpful.

00:06:04 – 00:06:42 – Kyle Murchie

I think on that. They’ve also got, I believe some demand data as well now at an aggregated level, which is great. Obviously, a lot of talk about demand recently and there’ll be more and more on that as we go forward. You know, go back even a year ago, we’re about 42 gigawatts across T and D, we’re now 125 gigawatts across T and D with about 75 gigawatts worth of data centres.

But even putting that aside it still leaves a significant chunk for other demand. So having some visibility of that is a real step forward. And I know we’ve got a few points as well on demand related updates.

00:06:43 – 00:08:11 – Catherine Cleary

Yeah, well I suppose, the other kind of Connections Reform related demand piece is that customers who have an element of demand within their project who are going through the Gate 2 to the whole queue process at the moment will have had an email within the last week or so which is an RFI that’s come out from NESO which is asking supplementary questions about that demand.

So, what is the kind of final demand element of your project, be it for a data centre, for hydrogen, all sorts of other things. And there’s quite a lot in that questionnaire, which I think probably the feedback we’re seeing is that some developers are finding it quite hard to answer that.

So, it’s not just about factually what is your demand. It’s also saying would you be happy to consider things like ramping agreements or stage non-firm agreements. So quite a lot of like commercial strategy questions and I think the challenge with these RFIs, especially coming at this kind of time when people are quite sensitive to what they’re about to get and a Gate 2 offer, is that unless there’s a kind of an explainer document almost alongside saying, well we’re asking you these questions for the following reasons and this is what we’re going to do with the information.

I think we see developers naturally clam up a little bit and think, well I don’t really want to share this unless I know how you’re going to treat it or understand what the implications would be if I told you something and then actually the project progressed and it changed. So, I think, I guess that’s something that there might be a few more of those kinds of clarification RFI type things coming out in future. And I think we’d love to see that kind of explainer document alongside.

00:08:11 – 00:08:15 – Kyle Murchie

I take it there is no real clarity on where the information is going to go once it’s collated?

00:08:15 – 00:08:26 – Catherine Cleary

Not that I’ve seen, no. And I suppose, linked that for demand customers, the things like final sums, so, Kyle, I know you’re quite close to the Code Mod CMP417.

00:08:26 – 00:08:46 – Kyle Murchie

Yeah, so that’s an interesting one. Actually Pete’s, now sitting on the working group and the working group has moved forward. So, it was paused and restarted after the Connection Reform, Mods. But we were just looking at it earlier. It started in mid-2023 and the final report isn’t expected to go to Ofgem until September 2026.

00:08:47 – 00:08:55 – Catherine Cleary

Blimey! So yeah. And it was meant to be a simple Mod. It’s an urgent Mod!

00:08:55 – 00:09:38 – Kyle Murchie

Yes, yes. So, the working group consultation is opening up now, which is great. So, there’s opportunity certainly in the coming weeks to start feeding into that more and more. But then there’s a massive gap between the workgroup consultation, then the code admin consultation, and then obviously moving towards voting and, the working group report being submitted.

So, while there’s an opportunity to close that up, I’m aware that the CUSC panel didn’t support the timetable that was presented. So, there may be some change yet to come on that one. But it is just flagging that based on that timetable that’s proposed. If you’re getting an offer through the Connections Reform process for demand and you’re under final sums, it’s not going to change in 2026 based on the current timetable.

00:09:38 – 00:09:40 – Catherine Cleary

So, your liabilities would still be based on final sums.

00:09:40 – 00:10:00 – Philip Bale

And obviously it’s going to continue the issue of first come, first serve. So, the projects are in earliest, will have the least issues, and the projects at the back of the queue will have the biggest impact because of all of the other projects ahead of them in the queue. So, we could end up seeing some very, very big securities and liabilities for the projects that have only just accepted as a result of all the other schemes ahead of them.

00:10:01 – 00:10:12 – Kyle Murchie

Yeah, and also a lot of projects under final sums that effectively are securitizing everything, but potentially assets that ultimately are then you, end up getting shared. So, you know …

00:10:13 – 00:10:14 – Catherine Cleary

So over securitizing.

00:10:14 – 00:10:44 – Kyle Murchie

Oversecuritizing, we recognise that it was an issue. It’s been recognised for quite some time, hence the Mods and hence why it seems quite straightforward. And there are some little things in there that maybe make it a little bit more difficult. Like if you change one aspect of the code, does that then have a negative impact on generation? Some of the potential changes you could end up putting actually more liability on generators if you’re taking it away from demand.

So there’s definitely some complexities to think about, but it’s not compared to a lot of the Code Mods. It is one that just needs a bit of focus and a bit of traction.

00:10:45 – 00:11:16 – Philip Bale

And the one thing I think it really needs to be thinking about is for distribution customers that are going through which distribution customers go through that TIA impact and a massive swing between the different DNOs.

Some of them are saying any demand above 1 megawatt has to go through a transmission impact assessment. Others are saying anything up to 50 megawatts doesn’t need to go through that process. And then how they deal with the cumulative impact of it, what goes on the Week 24 return, which goes for a transmission impact assessment.

It feels like there’s something that needs more standardisation between the different DNOs.

00:11:17 – 00:11:33 – Kyle Murchie

Yeah. So I suppose a similar sort of concept to CMP448 was it? And 446. Sorry, yeah. 448 was the PCF, wasn’t it?  On the TIA threshold, because that only applies to generation. So maybe something that’s …

00:11:37 – 00:11:45 – Philip Bale

And I know various DNOs have asked the TO, where should the limit be? And never got a clear answer. So, I think that’s something that does need to come and I think it is important for it to be well considered and to be consistent.

00:11:45 – 00:11:55 – Kyle Murchie

So, on the topic of DNOs and still kind of Connections Reform related. I know Philip, you were talking earlier about milestones. Do we have an update on?

00:11:56 – 00:12:42 – Philip Bale

So, I think, Catherine and I have just come off the webinar. I think I had started this beforehand because there’s been guidance that’s been released. I think it came in in October. And the idea is that guidance goes through and makes the milestones far stricter for customers. It goes through and explains the timescales for each of those projects. And I think based on the written guidance, it has concerned a lot of developers that the written milestones that are in there are very short and look very inflexible.

And as an example, from getting planning permission to having a construction plan to doing a ICP design submission being within six months. But I know Catherine, on the webinar they made that much clearer. Which doesn’t come across in the guidance.

00:12:42 – 00:14:40 – Catherine Cleary

Yeah, I think and I suppose in some ways a lot of these numbers haven’t really changed to what distribution customers have previously had in their offers. But some of the kind of process around we used to have a kind of concept of sort of like cumulative tolerance and that’s now changed. So, it’s the terminology is kind of remedy, and those remedy periods are shorter.

So, it sort of looks like there’s less wiggle room I think from the documentation. But I would say that the ENA, held a webinar today, which did sort of flesh some of this out. And I think some of the really clear examples were that there were quite a lot of caveats. So, things like your planning submission, you need to make a planning submission within two months of receiving a Gate 2 offer, for example.

But actually, if you’ve got pre planning activities where a planning authority said you need to go and do a bird survey and it’s going to take you 18 months, you’re just allowed to add 18 months to that process. So, I think there are some quite clear examples where if there is a specific kind of justifiable evidence or reason why you’re outside those time frames, I think there are processes to take that into account.

And I think on the example which has been sort of repeatedly highlighted, is that for some of the larger connections, as you say, Philip, I think that kind of. Okay, well everything’s sort of done and dusted, I’ve got my planning consent now I should just be able to kind of go into a build it. And we know that doesn’t happen with things like overhead line tower surveys that might take 18 months for a DNO to do.

So I think the messaging back today, is that although on a timeline M5 and M6, which are the construction plan and the ICP design submission, they appear aligned, but they can be completely decoupled. So if you agree and submit a construction plan, which you agree with the DNO, that says, well actually you’ve got to do this 18 months worth of work and then we’ve got to confirm some of the kind of planning impacts or siting impacts, for the substation design and then we can submit a design then actually you just work all of that into a construction plan. The project is clearly progressing and that’s acceptable. So effectively your milestone for the ICP submission moves in line with your construction plan.

00:14:40 – 00:15:57 – Philip Bale

What’s interesting though is often I’ve had with network operators, including myself when I was there, people are much more considerate of planning and technical reasons for projects being delayed, much less considerate around financing implications.

So as an example, most people will know that the vast majority of the projects that are being developed are originally conceived by developers, and they are usually not the people who build them and own them and operate them. So, after planning and after that project is being de-risked they normally get sold. And that period can be quite difficult to explain to a network operator of why, why it appears like the project is ready and why it’s not got an ICP submission, why it’s not got financial close, why it’s not going into construction. Because the person buying the project will want to put their own favoured ICP on there and they will be the ones that are going through financial close on the project.

And that’s one that I think the network operators don’t get their head around. And it’s quite difficult for anyone to say what is a sensible amount of time for a sales process when a project appears ready to build. And that’s something that I really don’t think is clear in the milestones and I’m not sure was picked up on the webinar.

00:15:57 – 00:16:47 – Catherine Cleary

There was a comment on the webinar to that effect. And I suppose perhaps just being devil’s advocate, you know, perhaps as an industry we also don’t want there to be a kind of open-ended opportunity for projects to sort of sit around in that transaction space for an unlimited amount of time. So, you know, I suppose you could, I think you could say actually, you know, that six-month period it sort of sets a framework and it gives the industry something to work towards and I think there is that kind of flexibility when it comes to the engineering construction plan.

But perhaps, you know, I think some of the commercial drivers will take their lead from those milestones, you know and we do see things like ICP preconstruction design awards, you know, where you might provisionally award a contract of a limited value, before you’d financially closed a project to start some of those things moving. So, feels like I think there should be solutions.

00:16:47 – 00:17:17 – Philip Bale

I think there should be, and I think it’s just making sure that the elements that come from the webinar end up going into the technical documents that the network operators will use to judge the project against its milestones.

So, I think at the moment the documentation needs to catch up with the spirit of where it’s intended.

00:17:08 – 00:17:47 – Kyle Murchie

Yeah, I’m just thinking about the earlier milestones as well, because those are the ones that quite often, we talk a lot about Gate 2 and therefore a lot of the earlier milestones. You’re already past those by the time you get to Gate 2. But I’m just thinking back to CMP434, Alex, that we were both sitting on and there was quite a big piece of work done, wasn’t there, on how long does it actually take projects to get through planning and whether that was DCO, Section 36, 37 or Town and Country.

And it’s interesting that that’s probably one of the biggest pieces of work that’s happened recently to try to look into what does it actually take. But yet the milestones don’t align with that, do they?

00:17:48 – 00:17:52 – Alex Ikonic

Yeah, definitely not reflected at distribution. So, at distribution, the milestones are very much kind of across all DNO projects. So it’s the two months after you accept the Gate 2 offer. So, yeah, there’s a big mismatch between D and T there.

00:18:02 – 00:18:11 – Kyle Murchie

Yeah, because I forget exactly what number it ended up landing on, because I think there were quite a few numbers that kind of got floated around. But was it 18 months or something like that, for town, between 12 and 18?

00:18:11 – 00:18:50 – Catherine Cleary

Yeah. For town and country planning, all the way up to five years plus for a DCO. Yes. And I think that’s another point that again is kind of clear in some of the discussions, but maybe not in the written guidance documents. You know, these milestones are, I think, realistically based on English Town and Country planning assumptions.

So, you know, so we’re talking sub 50 megawatts. And actually, some of those devolved administrations have different, very different planning systems. Some of the larger projects will have very different planning timeframes. I mean, it feels a bit like maybe like a kind of, here’s a bit of a sort of like developer experience lived version that goes alongside the guidance doc. You know, these, this is the guidance, and this is actually some of the, some of the common issues that might come up which would be helpful for DNOs as well.

00:18:51 – 00:19:21 – Philip Bale

And one of the network operators I was with on Wednesday of last week said exactly that, that they were going to take a couple of projects that had already been built and then look back through that process and work through the timelines in terms of where they are.

I do agree with your earlier comment though that potentially we need to make, if there’s a sales process it shouldn’t be open ended and that will maybe focus people, but it needs to be realistic and in reality, six months between a project getting planning to that sales process with the de-risking activities as needed is way too short.

00:19:21 – 00:19:53 – Kyle Murchie

So, it sounds like although Connection Reform has been effectively set based on methodologies and a lot of the policy documentation quite some time ago now actually it’s still very much mobile and moving and actually kind of thinking about that around timescales.

So, what are we looking at from an offer point of view? So, Alex, I think we talked about this a little bit earlier, didn’t we? Around how long if you’re a transmission, connected party, how long will you have to accept your offer? And similarly, for…

00:19:53 – 00:20:34 – Alex Ikonic

Yeah, so I think we should start to see transmission offers come in the end of this year. So yeah Q4, 2025 and the distribution offer should start to come in in Q1. So that’s just for projects connecting 26, 27 and expect all of them to have three-month acceptance periods for transmission and four weeks or maybe some variation to that for distribution offers. So yeah, it’s still a developing picture, I think. Then yeah, I think we’ll have more offers kind of by Q2 and Q3 for distribution. So, it’s yeah quite an elongated process I think.

00:20:35 – 00:21:14 – Kyle Murchie

Yeah. And just thinking about what we’ve been talking about here, you know there’s lots of potential changes. It’s not necessarily, I think what the term variation was mentioned quite a lot previously but really if milestones are changing potentially costs might be changing, somebody knows have put that forward, dates are going to change, the template of the offer might change. That’s just a different offer, isn’t it? Yeah, and if you’ve got one month in which to review all that and kind of feedback and get changes made, that’s tight. And actually, I suppose even when we’re thinking about it on the transmission side you think oh great, we’ve still got the three months, but I think a month’s been mentioned, hasn’t it around TQs.

00:21:14 – 00:21:23 – Alex Ikonic

Yeah, we’re expecting the four-week limit to submit TQs back to NESO if you have any for your transmission offer.

00:21:23 – 00:21:28 – Philip Bale

Yeah, we have to be optimistic the offers will be perfect. There won’t be any need for any changes. It will be exactly where it needs to be.

00:21:29 – 00:21:37 – Catherine Cleary

I just hope that, does this mean that NESO are also co-committing to four weeks to turn around the answers to the TQs? That would be nice. I’d like, you know, I’d like to split.

00:21:38 – 00:21:39 – Kyle Murchie

Well, not eight weeks surely.

00:21:39 – 00:21:45 – Catherine Cleary

90 days. You know, four weeks for our questions, four weeks for their answers, four weeks for everyone’s. Everyone’s mutual satisfaction.

00:21:46 – 00:22:20 – Kyle Murchie

Yeah. But it does lead into I suppose a good question around issues that are already known because we’re aware of certain projects that didn’t quite manage to resolve issues that were already there. The difficulty is who do you speak to now to try and resolve those?

But I suppose the challenge is what can be done now in the time between now and getting the offer to try to mitigate that as much as possible so that, you know, I suppose it’s maybe a rag status of projects which would you think are going to be relatively straightforward and which are going to be the most challenging.

00:22:20 – 00:22:41 – Philip Bale

I think on that it would be nice that some of the projects are aware where there are issues in their legacy offer. Ideally it would be nice if the same mistakes weren’t carried over to their new offer. So, it feels like at the moment that potentially it’s missing a trick to then repeat the same mistakes again and then to need Mod App to then go through and vary or an ATV afterwards.

00:22:41 – 00:22:42 – Kyle Murchie

Absolutely. So, thinking about those topics there that we’ve covered, is there anything else that we want to flag? Particularly thinking if people are sitting there with offers coming out in the not-too-distant future?

00:22:44 – 00:24:23 – Catherine Cleary

 I think the one thing, well sort of, sort of related to offers but I think just in terms of timeliness we would really like to flag this Grid News and Views is that there has finally been some movement on SGT charging.

So in particular, so distribution customers who’ve got transmission costs in there for new SGTs or even brand-new grid supply points, and your Gate 2 offer might still reflect those assets being required. There’s obviously a CUSC Mod which is sort of being raised and is starting the process, the workgroup process, but will be quite a long duration CUSC Mod again.

So not kind of coming out in time for Gate 2 offers but in the background there is also a DCUSA Mod, looking at the tools the distribution network operators could use to potentially socialise those charges entirely. So that would mean rather than one customer being burdened with £15 million for an SGT upgrade that might go to zero and that cost would be recovered through all DUoS charges in that region.

The other options are things like a cost apportionment factor. So, things which we’ve talked about before on other podcasts, that DCUSA Mod is moving quite fast. And it’s currently out for its first consultation. It ends on the 28th of November. So, it’s DCP461; we’ll do a LinkedIn post to it. There are eight options on the table, and the purpose of this consultation is to sort of narrow down the options, sort of get a feel for what people prefer. So, it’s not quite as sexy as some of the CUSC Mods, but I would really flag that one as one to respond to.

00:24:24 – 00:24:34 – Kyle Murchie

Yeah, because it could be quite a quick win. Because the intention is really that this is. It might be the enduring solution, but also might be the short-term solution, but still from a positive point of view, it’s reducing the burden.

00:24:34 – 00:24:47 – Catherine Cleary

Exactly. From a customer perspective, actually, I think a lot of our customers will be fairly agnostic as to whether this is socialised through kind of distribution charging or transmission charging. They really care. How does it turn up in my offer? And this is another solution to solve the same problem.

00:24:48 – 00:25:05 – Philip Bale

Brilliant. Will the DCUSA Mod and will the solutions consider what is done, where and if it should be changed? Because obviously the CMP proposal could look at that in terms of, we should be doing the right thing in the right places and socialising the assets in those areas. Does the DCUSA Mod include that or is it going to be?

00:25:06 – 00:25:57 – Catherine Cleary

So, bearing in mind the kind of scope, the, limitations on scope, a DCUSA Mod can only really change how a DNO deals with costs are passed through to them. So ‘t make any assumptions about, how transmission charging might change.

So, for example, at the moment we have infrastructure sites where those charges are already socialised at transmission and customer connection sites where they’re not. So, this Mod is sort of assuming all of that stays the same. So, any kind of changes at transmission level charging out of scope, but says, right, well, if the DNO gets a bill for that 15 million, how does the DNO deal with that and splits it between its customers, and what happens if some of those customers drop out? And who bears the kind of residual. So, it’s one step down from that, but it makes it a kind of simpler Mod to process, and I think to get some really, really useful industry intel.

00:25:58 – 00:26:19 – Kyle Murchie

Yeah, because it’s worth saying that the CUSC Mod wouldn’t really be. Well, it’s only kicking off, I think, tomorrow. Yes. So, you’re sitting on that one Philip. And but it’s not due to actually prepare or provide our report to Ofgem until late next year. So, we are looking at a much longer-term view but hopefully something for longer term benefits.

00:26:20 – 00:26:21 – Philip Bale

But it’s good that it’s starting, finally.

00:26:22 – 00:26:29 – Kyle Murchie

Yes, yes. I feel as if we’ve been around this table a lot talking about SGT Charging for many, many years and it’s really good to see.

00:26:30 – 00:26:31 – Catherine Cleary

Now we’ve got some company.

00:26:31 – 00:26:4 – Kyle Murchie

We’ve got some company. Yeah. Other people really talking about it and there’s a route forward which is, which is great. I know Philip, you had a couple other points?

00:26:41 – 00:29:16 – Philip Bale

Yep. So, one of mine is more around things that are already connected or going to connect at the other end because there is still a lot that’s going through that’s being connected and active network management, a few things on that.

Number one, I think there has to be a lot more focus on the network operators being really clear on where the constraints are, how they’re setting up their ANM scheme, what the rules are. Because ultimately customers connecting to an ANM scheme shouldn’t be writing a blank cheque where the network operators can add extra constraints in at any time, can change the configuration of the ANM scheme and potentially significantly increase the risk for themselves from when they were connected.

There is a definite need to consider how to manage fast acting battery storage in those ANM zones, making sure that the diversity between the storage and the other generation can be taken advantage of. We’ve heard stories of ANM schemes being pre-configured so that even when a battery is importing the ANM scheme is being configured as though it’s exporting because it can operate so quickly to pre constrain other generation.

Which then goes against the whole aspect of why ANM was put in place which was around the diversity of them. And the other one, which is not ANM, is I think there needs to be a lot more conversation around abnormal network running and how it can be done more fairly.

One network operator, they reconfigure networks for demand reasons. If you take an SGT out, you may reconfigure your network. So, if you’ve got a second SGT outage you don’t overload it, you don’t have the lights go off. So, you reconfigure BSPs to other networks and move them all around the networks.

And in the past it’s been quite easy to do and just leave the generation as it is. We are starting to see some generation customers being turned off under those scenarios and where they have ANM, where it’s not being used because the ANM scheme is not being configured. And the question is, if you have a GSP outage over here and you have a BSP over here that is two or three removed from the outage, is it right that those customers get constrained and how much should the DNOSs be telling these customers this is going to happen? How much limits and just making it very clear. And that’s something that I think we’re going to start to see more and more and more, which is people are going to get very upset because of abnormal network running, especially when it’s not on the GSP that they’re connected under. And SGT outages is one of the key ones. They happen typically for six to eight weeks every three years and it’s routine and it’s a real problem.

00:29:17 – 00:29:29 – Catherine Cleary

Is there any mandated reporting of abnormal running? So at the moment a DNO doesn’t have to sort of tell Ofgem or anything retrospectively. By the way, I ran my networks abnormally for you know, 25% of last year.

00:29:30 – 00:29:45 – Philip Bale

Not as far as I’m aware. I don’t think there is anything. It’s something that they could report on, but I’m not sure they do. Some DNOs are starting to publish more. I’ve turned these customers off under ANM, but I’m not sure they’re reporting on – I’ve turned these customers off under abnormal network running.

00:29:46 – 00:29:56 – Catherine Cleary

It’s the bottom line of every curtailment assessment, isn’t it? This is only considered normal network conditions. I think it would be something that would be really useful for the industry to know how often networks do run abnormally?

00:29:57 – 00:30:26 – Philip Bale

I would say there is no normal running because normal running changes all of the time with networks being reconfigured and going through.

So abnormal, is normal, but the level will very much depend on each particular network and also the views of the people doing it and the risks. It makes a difference of when an outage is taken. How much do you have to turn off in order to stop the network from being overloaded?

So yeah, something that I think we’re going to pick up far more in the future. Something that I think needs to have far more transparency for customers.

00:30:27 –00:31:05 – Kyle Murchie

And talking about data and transparency, you know, we’ve talked about it there, we’ve talked about it from a, connections perspective and Gate 2, we’ve talked about it recently.

I was at conference last week on innovation and it was a lot of discussion around data and how much information that needs to be shared between innovation partners and get that into BAU. So, yeah, on that point on data, we’ve obviously been asking a lot of industry at the moment on data whether that’s innovation related data, connection related data. So if we had the ask of what data do we want to see what do we think needs to be out there and more transparent?

00:31:06 – 00:32:00 – Catherine Cleary

We’ve talked a lot about demand, the lack of demand data so that be that either operational assets or more commonly kind of the contracted demand key which we don’t publish at transmission or distribution. I think we should probably flag, there is another company called Yottar who are doing a lot of work in this space kind of lobbying.

They’ve written an open letter which we totally support and have been involved in some conversations around actually what are the levers that Ofgem could pull to just resolve some of the confidentiality issues which DNOs have really seemed to kind of effectively either used as excuse or really felt were a barrier to them publishing that data.

So that’s got some really positive suggestions. There could be an update in fact to the long-term development statement clause which is effectively a requirement in licence conditions to sort of facilitate the publication of that demand. I think that’s kind of gained some really good industry support. So yeah, demand data.

00:32:01 – 00:32:41 – Philip Bale

Just on that UKPN are publishing that so they have their large, accepted demand data that’s in there already and is linked on BSP’s and primaries. They also have their connections lab which also includes in the background the accepted demand data which then means that you can go in on the EPN and the SPN networks model it, model generation, model demand, and it will take into account the large embedded accept the demand data within there.

So, they are by far the leaders of the publishing demand data. But yeah, doing just the LTDS update one year out of date, possibly more in terms of going through it makes it impossible for people to make good engineering decisions.

00:32:42 – 00:32:46 – Kyle Murchie

It’s almost like an ECR type approach that we really need to see, isn’t it? Just another table’s there.

00:32:46 – 00:33:01 – Catherine Cleary

Yeah. So, I think. Sorry, sorry to be clear that the suggestion in the open letter was more around using that sort of tool which says networks you must publish information to require something like a fortnightly register or a bi-weekly register. So just using that as a tool but much more frequently.

00:33:02 – 00:33:31 – Philip Bale

But on there I think it’s also interested not only the accepted demands, also the customers that have unused ASCs where their agreed supply capacity is taken into account in network planning, but the real data will be based on what they’re actually doing. So, it can be very misleading where a network looks like it’s got plenty of headroom, but then they say oh, but I’ve actually got a connected customer I can’t tell you about that is not using anywhere near their ASE and therefore you can’t have a connection as a result of that. So, I think that’s something also not to miss.

00:33:02 – 00:32:55 – Catherine Cleary

Kyle and Phillip from your old network operator hats on, do you see there’s any sort of downside to publishing that information in terms of sort of security of supply or network security? I think there is an increasing concern, it comes up a lot sort of cybersecurity, that a lot of this data is machine readable. Is there a kind of risk that it can be used by mal agents?

00:32:58 – 00:34:43 – Kyle Murchie

I mean my initial view is no, because you can always, I mean ultimately you could try to work out you know, you know a factory exists there, so you know it’s going to be taking a sizable amount. But I think what we’re seeing is quite a big change from what might traditionally be used by a factory or distillery or whatever the business is to what they might need under decarbonization. So, the fact that it’s you know, gone from some hundred, a couple hundred KVA to a couple of MVA, that’s really only, the only really use for that information is from a network perspective, network planning and just understanding what’s there, knowing that it’s 5 megawatts from a security point of view, I think it’s probably a bit neither here nor there. But I don’t know if you’ve got any other thoughts?

00:34:44 – 00:35:16 – Philip Bale

I think there’s information, so every large demand customer will have their information published in a EDCM table which you could use to work out which are the largest demand customers.

Some network operators will list the scheme and the name and the customer. Some anonymize it which then makes it more difficult to work it out. So, I think there’s a big mixture that’s in there. I get that it could have some commercial sensitivities in terms of what’s going, but I’m not overly concerned in terms of cyber security from that basis.

00:35:16 – 00:35:32 – Kyle Murchie

Yeah, I suppose you think batteries, you already see that already from a demand point of view it’s already all the DNOs know, so we’re obviously making the assumption that data is extremely, if you’re really wanting that data you could probably get access to it.

00:35:33 – 00:35:44 – Philip Bale

And I think in going forwards the publication of the SIM models that will be in there anyway. So, the more publication of data it has to be in there. And ultimately if we want people to make good decisions, we need to publish the data.

00:35:45 – 00:35:58 – Kyle Murchie

So, on the demand data side, so it sounds really positive but do we have any idea of timescales or what the next steps are like I should know. But LTDs, how quickly can that be changed in terms of the rules in the background? Is that a licence change or?

00:35:59 – 00:36:01 – Catherine Cleary

Maybe we might, maybe we’ll have to do another podcast on it.

00:36:01 – 00:36:06 – Philip Bale

I think I’ll just put it out there. UKPN are already doing it, so they obviously don’t feel like they need to have a licence change, they’re just doing it.

00:36:07 – 00:36:39 – Catherine Cleary

Yeah, I think some of the, just going back to the kind of roundtable conversation with Ofgem and some other parties, I think there was a feeling that actually other network operators didn’t agree with that and there was need for there to be either a licence condition, that was kind of override some of the Utilities Act, sort of confidentiality, requirements, which is what the ECR currently has.

So, the ECR is a licence condition, and the licence condition overrides anything in the Utilities Act which says thou shalt not talk about individual customers. So, I think differing DNO opinions.

00:36:40 – 00:36:46 – Philip Bale

But they are able to do it in a way where they’re not talking about individual customers, they are grouping them in such a way that you can still work it through, and so that’s what’s published.

00:36:47 – 00:36:59 – Catherine Cleary

I suppose. So that could be a halfway house, couldn’t it? Because you could say, right, we’ll do that now. But in the long run, ultimately, I think we do agree that there is a need for an ECR type register which is per customer. So yeah, we would need a licence change or some kind of directive.

00:37:00 – 00:37:32 Kyle Murchie

Okay. I’m thinking about generation as well and also the information that we could ideally have coming out of Connections Reform. I mean it feels a bit deja vu that we discussed this in detail 18 months ago, through CMP 434 and 435 around all this data that we could release.

I think the answer then was none of that’s going to come out yet. But we seem to have gone back on that a little bit and maybe questioning well actually why and could be benefits of publishing some of this. So yeah, what’s our ask?

00:37:32 – 00:37:52 – Alex Ikonic

Yeah, so I think we will get some data in some form. So, we’ll get the EA register which is the existing agreements register. So, I think that will just tell us who of the existing queue has applied for anything in Gate 2 to the whole queue. So, I’m not sure that will even differentiate between who’s applied for Gate 1 versus Gate 2.

00:37:52 – 00:37:55 – Catherine Cleary

And was that the opt in so you could?

00:37:55 – 00:39:01 – Alex Ikonic

Yes, that was opt in as well. So, it probably won’t even be complete, and we will get some kind of amalgamated state outcome of the Gate 2 to the whole queue. So that’s to do with the zonal parts of Clean Power 2030 is and you know how full are they for individual technologies.

But it won’t sort of go into more detail than that. So, I think our ask is you know that’s a great start, but our ask is we need to do a lot more. So, you know whether that’s something like extending the tech register and the ECR as well. So just potentially adding in some columns to say this is a project that has a Gate 1 offer versus a Gate 2 offer. I think even that’s a useful start.

From TO companies, we’re also requesting something like the Tory Register or a more up to date transmission works register as well. So, something to have more detail on individual reinforcement works that includes their status and the description of the works as well and yeah just more information on that as well, kind of who’s dependent on which schemes as well.

00:39:02 – 00:39:03 – Kyle Murchie

Not just a long number.

00:39:04 – 00:39:21 – Philip Bale

Especially for distribution customers. So, distribution customers are subject to the enabling works, and their only way of engaging is via the DNO and more often than not when we ask the DNO they say go ask the transmission operator yourselves.

Which is not what you can do as an embedded customer that doesn’t have a BCA with the TO.

00:39:22 – 00:40:02 – Kyle Murchie

Yeah, I think it’s a good point. This data is important for multiple reasons, but I think one of the main reasons is actually just to do that sense checking in the best one in the world. Even if we get really high quality offers that are really accurate there’s going to be some percentage and even a couple of percent is still a large number of offers that have errors in them. But how are you going to know? It’s going to be obvious if it’s the wrong party’s name. But it might not be obvious if you’ve got the wrong data in there or the wrong works if you don’t have access to that kind of wider information. So yeah, for me it’s not just about thinking ahead and kind of build out and everything, it’s just actually doing that sense check.

00:40:03  – 00:41:12 – Philip Bale

The one thing I’d say is though, a lot of the data that we’d like more data to be published but it has to be good data, and you have to be able to engage with people to discuss the data. So as an example, I really don’t want to see another LTDS that has tap changer reverse power flow capability TBC for the last 10 years.

And I really don’t want to see demand forecast that has sleepy rural six MVA primary substations showing they’re going to have 50 MVAs worth of demand in five years’ time. And the crazy numbers that are coming out that was published last year in some of the network operators that hasn’t been fixed in a year and hopefully will be fixed very soon.

But even just some of the demand data that’s in there, that’s published online, in terms of the open data, it doesn’t make sense. So you need to have the capability of being able to engage with people and say this data is wrong and if you want people to use the data it has to be right and sense checked and sort of sanity checked elements to it so that it actually becomes useful because if not you can end up sending people down the wrong path with the wrong data.

00:41:13 – 00:41:41 – Catherine Cleary

So, data teams are quite key I think. We don’t really have that within NESO and TOs that’s not really a particularly visible function. Whereas not that UKPN sponsor this podcast, but UKPN do have a very visible data team. So, you are contacting a small group of individuals and saying actually this column doesn’t make a lot of sense you know, could you match it to this node reference or something? I think you know that resource allocation within NESO is something that would be really, really valued by the industry.

00:41:41 – 00:42:20 – Philip Bale

But even with the other DNOs, when you contact them and say this data is wrong and they come back to you and say yes, you’re right, this data is wrong, but they can’t fix it.

It will be updated, but it hasn’t been updated. And just for some people knowing who to contact because they know those parties is probably not the right answer. So, I think a visible data team, a visible data team with a data inbox with SLAs so that when you say to them this data is wrong, an agreement of yes, this data is wrong, we will fix it within 21 working days unless it’s extreme. And that extreme should have a defined time period.

00:42:20 – 00:42:24 – Kyle Murchie

Particularly if it’s your data. Like I’m just thinking of ECR.

00:42:24 – 00:42:25 – Catherine Cleary

We don’t mind about other people’s data.

00:42:25 – 00:42:30 – Kyle Murchie

But if you’re going in and going, what? Well, that’s not my project details, then that should be something that could be corrected quickly.

00:42:31 – 00:42:42 – Catherine Cleary

I mean, I think confidentiality issues. We’ve seen things published in the Tech Register that shouldn’t have been in there and I think there does need to be a speed of response to some of those issues.

00:42:42 – 00:43:55 Kyle Murchie

I think even in the short term with more data, we’re asking for more data, which makes it more complicated. But I think if we’re clear from the offset, well, if there’s changes need to be happening, that’s fine. Yeah, the ECR is the best source of data from a distribution perspective, from a But if the new data coming, out, what is the best source? So if we are saying, oh, connections point of view, then fine, it might be that the LTDS is still there for contractual reasons. It has to be published and has connections data in it. But if we all know that that’s not the place you look for that information in the short term, then that’s really helpful. What we don’t want is four or five sources of effectively the same information with different things, particularly if the offer is different from the, register as well.

So, yeah, big ask, but I think access the data teams would be quite key. Great. Well, I think we’re coming to a bit of an end to the podcast because we’ve been covering quite a lot of points, so anything that anyone else has to, put forward, let’s keep that and we’ll channel that into another podcast.

So, all that leaves me to say is thanks much everybody for listening to this podcast and, we’ll see you in the next one. Thank you.