The Big Reshuffle Question

00:00:40 – Hugh Taylor
Welcome, everybody, and thank you for joining us for what is the very first of the Connectology® debates as a podcast here. And this is an emergency debate because I opened up a bit of a can of worms on a webinar a week ago about the Connections Reform Connections Design methodology that’s proposed by the ESO. Some of you would have been on that webinar anyway and would have heard it. Essentially, Catherine said that, the intention is to try and maintain fair treatment of transmission distribution in their relative queue orders, so we don’t have huge swathes of T projects leapfrogging D projects, based on project progression date and not the distribution application date. And as a relative lay person that I am, my immediate thought was that that methodology would provide completely the opposite effect in terms of that fair treatment.

Kyle and Catherine then briefly spoke to that, but didn’t really answer the question necessarily fully for me, and somebody put in the Q&A that they sort of very much supported my position – that was James Daney, thank you for that. And then there was an awful lot of upvoting of that, and so I kind of realised that this is something that people feel quite strongly about. I then spoke to Kyle at sort of, quite a bit of length afterwards about it, and realised that this is an incredibly complex, and nuanced, and nuggety question in itself and that my, sort of very narrow view of the world wasn’t necessarily helpful. And because some of you are going to, want to be responding to the consultation which closes on the, on the methodologies, which closes on the 2nd of December, that we might just, all we can hope to do here is just give you a little bit more context than some of you might have; some of you will be right up the curve anyway.

So, unfortunately, in terms of Connectologists®, they’re all, bar two, are sort of out, doing sort of public engagements today. So, I’m afraid we’ve only got Catherine Cleary, and we’ve only got Pete Aston, so we’ll have to make do with those, and it all is being done in a bit of a rush.

00:02:53 – Catherine Cleary
Sorry Hugh.

00:02:55 – Hugh Taylor
That’s alright.

00:02:55 – Pete Aston
I know you’re scraping the barrel.

00:02:56 – Hugh Taylor
Yeah, very much so, and it is being done. I mean, it would have been great if I think with kyle and Philip. Phillip would have, I’m pretty sure what kind of position he would have taken on it, and Kyle obviously is kind of Mr Connections Reform – which would have been great.

00:03:11 – Catherine Cleary
Well, don’t fear Hugh. We have, you know, our geek chat behind the scenes, we have scraped their opinions. So, Pete and I will be doing a good ventriloquy act for some of the more strong opinions in the team.

00:03:23 – Hugh Taylor
Yeah, I’m really pleased. So, the geek chat is, the Connectologists® have a sort of a chat on teams and they also get together every two weeks and just kind of geek out and I’m not allowed in. But anyway, so that’s a complete aside. So, I never actually introduce, other than saying who we’ve got, I don’t actually kind of sort of speak to who the Connectologists® are, that are on any of the podcasts or webinars, because we have so many frequent flies. But I think it’s kind of relevant in this instance, so I’m going to.

So we’ve got Pete Aston. Pete was head of system planning at National Grid Electricity Dispute – WPD it was at the time, and he was responsible, as well as for the ongoing design of the actual high voltage network, he was also responsible for the relationship with National Grid, ESO and NGET at the transmission distribution boundary and implemented Appendix G. So WPD was the first of the DNOs to implement Appendix G and the whole project progression process from the DNO side. And Pete did it incredibly effectively and I think most people on here, who have experience of the way that WPD and NGED go about it, would probably say that it is streets ahead of the other DNOs, not sort of naming and shaming anybody. That was one of the reasons why I wept when Philip said that Pete was interested in coming to Roadnight Taylor. But anyway, and he also advised National Grid, ESO, as was on the technical limits process and protocols. So, he has a very kind of rounded understanding. He also looks after a lot of transmission and distribution projects that are sort of going through at the moment and grid connection specialist.

And Catherine, and both of you can jump in at any point, by the way, and correct me on any of this. So, Catherine sat on CPAG, the ESO’s CPAG, and I’ll let her say what that actually is in a minute, because I can’t remember what it stands for, and also spent about, I think, four years advising Ofgem as an independent expert and covered lots of things around sort of codes and the like doing of that, and has connected huge numbers of big projects, and looks after a number of transmission and distribution projects across. And both of them look after, and I think this is quite important, a lot of projects for a lot of different parties at distribution and transmission, across a lot of technologies and geographically dispersed across the whole country as well, which makes them kind of pretty independent as well.

So, what I’m kind of looking to achieve from this, what I hope to get from this debate, is if a developer who has an entirely balanced portfolio of projects across transmission and distribution, across a spectrum of technologies and geographically dispersed across the country, with a spread of land and planning statuses. So, this is ideally what would take, what I would like to get, is that somebody who is heavily invested but absolutely doesn’t have a dog in the fight, as it were, completely balanced. So this fictional figure, who might serve as a proxy for somebody who is completely sort of balanced but invested, that at the end of this, they might be hopefully better equipped to take a position on this themselves and for that, to better inform their response to NESO on the 2nd December, and also any lobbying that they that they might be getting into. So hopefully it’s going to kind of clarify things.

It was interesting, I popped onto LinkedIn yesterday that we were going to be doing this and said would anybody like a link to it, because it’s all happening very quickly and people might want to hear it in time so that they can actually take it on board before they respond, and I was completely inundated on LinkedIn. So, it is clearly something that people feel strongly about, and you know, I think it’ll be very interesting to see how people feel about it after this. Right, normally you hear very, very little from me and I feel like I’ve slightly taken far too much time. So, the way that we’re going to run this as a debate, the first one I’ve asked ChatGPT (who is my new best friend), how we should go about this – I’m going to be following sort of a vague process,

00:07:36 – Catherine Cleary
He hasn’t told us by the way – so we’re on the fly.

00:07:35 – Hugh Taylor
Excellent. Yeah, well, I mean, I’ve only just done it five minutes before the call.
So first of all, hello, Pete and Catherine.

00:07:42 – Pete Aston
Hello, Hugh.

00:07:42 – Catherine Cleary
Morning Hugh.

00:07:46 – Hugh Taylor
Nice to see you PA, and CC.
So, it’s said though I need to welcome the listeners -I’ve already done that, I’ve introduced a topic, and I’ve introduced the two expert guests. ChatGPT thinks you are, but maybe I’ve suggested you are. So, we’re going to start with opening statements, now Pete is going to start on the distribution side, as though he is arguing for, the essentially, I think it’s the queue position to be based on the application date at distribution. So that’s that kind of a piece can start that position. And Catherine is going to start the debate from the position of supporting the queue position being based on the application date at transmission; so that’d be the application.

00:08:26 – Catherine Cleary
Sorry Hugh, can we just, is it worth us just outlining what the current proposal is, because the current proposal is that, which is what we said in the webinar, is effectively that once the filters of whether a project is ready and whether a project is needed have been applied, so kind of like shaking the queue through a colander, lots of projects have fallen out. The current proposal from NESO, is that all of those projects still in the colander, will get put back into the existing kind of GB wide queue order that NESO hold, which is either – the date you signed your offer if you are a transmission customer, so the date of your BCA, for example, or the date your DNO signed and agreed the Mod offer they got back from National Grid as a result of the project progression, so it’s not the date the project progression was submitted, it’s the date that the DNO signed it.

00:09:14 – Hugh Taylor
Right, okay, so from my perspective that sounds a little bit worse, but anyway. So thank you for that.
So CC is going to take the transmission position.

00:09:28 – Pete Aston
I think there is something I’d like to dig into around that process at some point with Catherine on this call, on this podcast. So it’s just some of the nuances to how the process thinks it’s going to happen. But maybe we can sort of pick that up as we go along.

00:09:46 – Hugh Taylor
Cool, and if I can just say, I know this is a complete aside that, I think it’s a an extraordinary task that NESO has, has got and has been sort of saddled with and I, you know, I look at sort of what they’ve come up with and I think, actually, in so many ways I think it’s absolutely extraordinary they came up with it so quickly, and I think in so many ways it’s really, really elegant. And I look at the bingo board and I just think, wow, that’s so clever, it’s not quite the London tube map, but it is, I think it’s amazing, I think it’s the thing of beauty in so many ways, it you know, it’s bound to be flawed in ways as well. But I think, first things first, I think they’ve done an amazing job and, and you know, I quite understand why some people might be unhappy with elements of it, but that’s kind of, you know, a bit of an aside, that’s my position.

So, right back to the main event. So, we’re going to start with PA, who is going to give an opening statement, and so I think sort of kind of up to five minutes max, PA on your position please, okay?

00:10:55 – Pete Aston
I’m going to quote two of my colleagues Hugh in this, who are Nikki and Philip, I’m sure they won’t mind me quoting them, but that I won’t say which one is which. One of them says it would be inexcusable not to rectify a wrong in relation to using the project progression dates, rather than the distribution dates, and the other says it is irresponsible to use project progression submission dates as many of them were delayed by the DNOs or NESO.

So if that’s not stating a very strong position, I don’t know what is. So, yeah, so I think defending you know, supporting the using the DNO application viewpoint, I think is a very easy one in a sense, because you go well, everyone in the queue should be treated fairly and that fair treatment should be based on when you initially applied to your network operator. You know the fact that, as a distribution customer, there’s some other layers of process somewhere up there, between the distribution companies and the transmission companies – that’s not my problem, that’s for them to sort out, but you know, I applied whenever it was three years ago, and that’s when my date should be in terms of any queue ordering. So, I think that does feel fair.

I think, from a lot of DNO customers, the sense of a slight delay between DNO application and transmission application is maybe something that could be tolerated. I think what really gets people, and understandably, is the large delay that there has been on lots of projects in lots of areas, between their DNO application, and then the project progression application. You know, in some instances it’s easily 12 months; you know, we know of stories where it’s been more like two to three years at the extreme, and so that does leave a massive gap between when the distribution customer applied, and when the transmission sort of what companies knew about the application, and obviously leave lots of gaps for direct transmission applications to have come in and effectively jumped the queue. So, I think as an opening statement we can probably stop there, because it’s a fairly simple one really Hugh, is that you use my original application date because that’s the fair thing to do.

00:13:19 – Hugh Taylor
Yeah, and that’s a great opening statement.

And I just actually, Ed Birkett, who, at low carbon I’m sure that lots of people on here would know Ed; he said that they had a site, they applied in 2020 and it was submitted for product progression in 22, invoice for the project progression in 2024 at the 2022 rate as well. So, yeah there, we could probably have sort of something on LinkedIn say ‘who has you know longer than however many months?’. And you know, I don’t think we should be getting into naming and shaming, but it has been, it has been pretty great. Thank you for that opening statement, Pete.

CC, can you do any better?

00:13:58 – Catherine Cleary
Okay, so to defend the proposed, not status quo, but the proposal. So I think, as Hugh says, there has been quite a lot of thought, and you know a huge amount of work that has gone into the current proposals. And if I was just to take that explanation a little bit further, with regards to that colander, the kind of sieve that we’re going to use to sieve the queue, there is effectively, there are two things going on here. One is, you know, the Connection Reform process is trying to effectively prioritise projects into that kind of Clean Power 2030 pipeline, and the beyond 2030 to 2035 pipelines to get things built, and which is obviously a huge shake-up. There are so many changes that come with Connections Reform but, balanced alongside that, is the risk of kind of massive investor confidence issues and sort of you know, bankability of projects – can anyone kind of progress and sort of investment hiatus? And so, I think that the proposed solution, which basically says, right, we’re going to sieve the queues, but then, once we’ve done that, if you are in the Clean Power 2030 pot for your relevant technology and your relevant zone, you’re a ready project, at the moment you know your project is not going to get worse than its current offer. So if I’m a solar project sitting in a kind of undersubscribed area of the distribution network, I have the confidence of knowing that I might get an acceleration opportunity, but I’m not going to get worse. So if I had a 2028 date, I could basically kind of carry on doing some development work, working towards that which helps to reduce the kind of risk of massive investment hiatus next year before everyone gets their revised connection offer.

And the reason that we can say people who are you know, if you’re confident you’re going to be in the pot, and you know that you’re ready, the only reason we can say that they’re not going to get worse is because we are putting people back into existing queue order. And when I say existing queue order, it’s exactly that kind of nuance – it is the queue order that NESO as the ESO have held, and this isn’t a new proposal; this is just how they’ve done it to date, which is that NESO determine queue positions based on the date that the relevant transmission agreement is signed. So, say that that’s either when a customer signs their connection application, sorry, connection agreement, if they’ve received it direct from transmission, or it’s when the relevant DNO signs the Mod offer.
And so by kind of keeping that continuity of queue position, we reduce uncertainty for projects, whereas as soon as we start saying right, well, actually we’re going to change queue positions as well, because it would be a change to what the current, we would be allowing projects. You know, you could be a project, you could both have planning permission, you could both be needed within your kind of CP30 technology pot, and you could have your land rights, but you might start leapfrogging each other just depending on how much delay there had been between a project progression being submitted versus your original application date.

00:16:51 – Hugh Taylor
Right. Yeah that’s, I’ll tell you what Catherine, I didn’t expect that’s where you would be going and that seems to me an incredibly salient point, that actually people have been making investment decisions based on albeit, that they might be very unhappy that it’s taken so long to get into and sort of through project progression, but they’ve been progressing on that basis. People with transmission projects have been progressing and investing based on the fact that they have the key position that they’ve got, and this has been going on for quite some time. Is that of, am I, that a sort of an effective summary of your kind of position there, or have I got that slightly wrong?

00:17:38 – Catherine Cleary
Yeah, no, I think that’s what I mean.
So, essentially, the risk here would be that if you, if you changed it, and I mean there are lots of pragmatic reasons why changing it might be quite complicated, which we’ll probably come on to as well, but high level, kind of the one of the reasons that the current proposal has been put forwards is to try and, like, minimise that risk, risk of disruption to people’s kind of who are, as I say, kind of in that needed and ready space. The one thing that you could say is that there’s obviously a higher risk, is just that right, you know you could benefit from this change, or you could, it could worsen your likely queue position. And I suppose you know what we’re, what we’re proposing, the specific change would backdate embedded projects, and therefore embedded projects will be more likely to benefit from this change. Transmission projects will be more likely to be disadvantaged by this change. But even the embedded projects that should benefit, some of them might benefit more than others, if that makes sense? So, you’re creating uncertainty even within the embedded queue. So, you know you might be thinking great, well, my project should get better, but actually if someone else’s project gets better, more (I don’t have a word for that), but you know than yours, because they had potentially, you know, not chased the DNO for a Mod App submission, or the DNO had, you know, had debated that Mod App result, you’re creating a huge amount of uncertainty into that queue and that has knock-on impact. So as soon as you start messing with the relative distribution queue positions of projects, you know, that has impacts in terms of who’s triggering what works what. You know. potentially things like the kind of LIFO queue stacks are as well for tech limits, something like that. So there are kind of quite intricate details that would need to be worked out if we change those things, whereas the current scheme, I think there’s quite an elegant balance of risk, tries to preserve, you know, those relative queue positions; we just get rid of the projects which aren’t ready or aren’t needed.

00:19:29 – Hugh Taylor
Great, thank you. Pete, could you, according to ChatGPT, I have to now ask you to respond to that please.

00:19:37 – Pete Aston
Yeah, I think sort of Catherine is almost bringing up the argument that I was going to bring up in terms of why the sort of developers with distribution schemes would want to have the queue sorted by distribution application date, is that I think it is acknowledged that, whilst it brings some uncertainty, there’s lots of distribution schemes that could get a significantly better date or a significantly higher up position in the queue as a result of this. And you know, if I’ve got a small portfolio distribution projects, well am I really worried about some uncertainty in the rest of the queue? My schemes can proceed, and you know, that’s for me, as a small developer, that might be in my best interests. Obviously, that’s a fairly sort of small sighted view of the world. But you know, if I’ve got a 2037 date and there’s lots of transmission schemes ahead of me, and I know that that was mostly because the DNO didn’t submit my project progression for two years, well, that still just feels like a very unfair position, and whilst this acknowledges that maybe if you go to distribution application date it might make some distribution applications worse, I think the general sense out there would be it would make quite a lot of them better in terms of transmission access date. You know, would it change things like, not only bring my transmission sort of firm connection access date forward but, if I’m going in under technical limits, does it actually improve my technical limits calculation? Admittedly, it completely messes up the technical limits calculations that have been done so far and I think that’s probably Catherine’s point as well as bringing in that uncertainty. But I just think that customers out there with a large portfolio of distribution applications are sort of probably, I suspect they’re thinking – okay, so there’s going to be a bit of disruption, a bit of disorder if we go to a different way of ordering the queue, but that’s just the fair thing to do, because at the moment I’m being disadvantaged compared to some other transmission schemes. yeah, so I think that would be my comeback.

If I can just raise a sort of additional point, and this is maybe more of a process point Catherine, that might just be worth digging into a little bit, because I might have got this wrong. But you know the pretty diagram, Catherine, with all the different coloured squares?

00:22:02 – Catherine Cleary
Yeah, the colour bingo slide?

00:22:04 – Pete Aston
The colour bingo slide for aligning the queue. So what that seems to do, is it lines up all the projects in the CNDM document, it’s got 15 squares, which are all sort, have all already been sorted for the readiness criteria, and then they get sorted with connection dates that are after 2030, and it goes through. So, my understanding is, Catherine, that each one of those squares could be a project progression?

00:22:35 – Catherine Cleary
Right.

00:22:37 – Pete Aston
So, do you think that that’s correct?

00:22:38 – Catherine Cleary
I think my interpretation, Pete, was that, so this is for anyone responding to the consultations, this is in the connection design methodology document, the CNDM.

00:22:46 – Pete Aston
Page 29.

00:22:47 – Catherine Cleary
5.7. Oh, there you go, page 29. Yeah, and it’s 5.7.

00:22:50 – Pete Aston
I’m looking at it now.

00:22:52 – Catherine Cleary
This to me is showing how a sub queue will be treated for a particular zone and a particular technology pot. So, this could be, well their example was short duration storage in zone in GBR, zone one. So, this is transmission connected short duration storage up in Scotland. So, they would do this for the transmission connected and then there is a relevant DNO zone, so the SSEN North Scotland DNO zone would do the same thing for energy storage, and you would end up with two queues, which are basically queues of projects that have met the 2030, if we just take that 2030 pipeline, so you would end up with two sets of projects. So, there’s one, two, three, four, five, eight and 13 were the projects that made it into the phase one queue and sort of 2030 queue at transmission. There might be another five project progressions that also, you know, with relevant technologies that also make it into that queue and NESO are proposing that they will then intercalate those two queues, so they will effectively place in the distribution project into the transmission queue in the relevant order, you know, based on the signed agreement dates.

So I guess the nub of what we’re debating is when they do that intercalation, should it be based on that signed acceptance date, or actually given we’re doing all this queue work in the first place, that intercalation is going to be a difficult manual piece of work, now is the opportunity to use a different date, and we could use the DNO’s date that the customer applied to them or perhaps accepted their offer, and we could pick something and do it based on that. That was my interpretation, Pete, so I don’t think that’s actually an example they’ve shown.

00:24:36 – Pete Aston
Yeah, no, I think that makes sense, because what I was thinking was in the example, in the CNDM, where it’s forming a sub queue for each technology and they’ve got the example of 1 to 15, I was just assuming that some of those blocks of 1 to 15 were potentially the project progressions, but you’re saying you don’t believe that they are.

00:25:02 – Catherine Cleary
I understand, this is from verbal conversations, so, you know, definitely a kind of clarification point. It’d be great to get NESO perhaps to do a slide which shows the example of how they will interpolate the cues at T and D levels. I think it’s a really critical question, isn’t it? But my understanding is that, no, they will be asking DNOs to do the first steps, one to five, of that of that kind of colour bingo slide; so doing all the sieving working out which projects get into the CP30 pathway – they will ask the DNOs to do all of that, and then resubmit into them a revised queue that goes to 2030 and they’ll just slot it into their queue.

00:26:00 – Pete Aston
Yeah, so basically you end up with, so the DNO will do their sort of colour bingo thing for each technology within their licence area, and then all of those that fit within the pot are sort of then re-bundled back into their project progression and then slotted in between, you know, maybe between transmission scheme five and eight or whatever it is, rather than individually slotted in amongst the.

00:26:28 – Catherine Cleary
Yeah.

00:26:29 – Pete Aston
Okay, no, that’s fine.
I was just assuming that one of those schemes, one to 15, was a project progression, or multiple ones could be, and then, and then I was confused as to how that you determine the planning status of a project progression, because obviously that’s not the thing.

00:26:39 – Catherine Cleary
Yeah again, I think there has been. So it sounds like there’s been quite a lot of thought that’s gone into that, but yeah, possibly not yet kind of outlined in a diagram.

00:26:46 – Hugh Taylor
Can I just, Pete you said that the transmission access date would get better for across distribution projects maybe not every project but would get better if the distribution application date was used in order to reorder the queue. So, if that, I’m pretty sure that’s what you said.
Catherine, I think this is a really important point. Should you give me what you think, whether that is the case and how kind of strongly is it the case? If that makes sense?

00:27:18 – Catherine Cleary
Okay, so I think there are two answers here. The first is that it depends, it’s we’re back to, you know, to be honest, a bit of a sort of network postcode lottery as to what kinds of reinforcement works you were waiting for in the first place. So if you’re the kind of project that’s been given a 2037 date because you’re waiting for there to be major new 400kV lines on the network, you know, this would really have an impact because actually that might just be because of the total cumulative level of generation, connecting and transmission and distribution across a really wide area like the south of England, and therefore if you suddenly shuffle your queue position up by two years because there was a two year delay in getting your project progression, suddenly you may no longer be triggering those works, and your connection date might come right back. So, there are some people who this would really, really positively impact. There are other people who are waiting for very localised specific works at a grid supply point, so that SGT upgrades. Now those SGT upgrades by and large are triggered by the distribution customers themselves. So, if you assume that a DNO in most cases you know, a DNO will have, even if they were slow at submitting project progressions, they should still have submitted project progressions roughly in their own DNO queue order; you know, in the order that projects applied to them. So, if you’ve got 200 projects underneath that you know are really oversubscribed at GSP and they’re triggering new transformers, then it doesn’t really matter if you move those whole, all 200 projects earlier in the queue, from a transmission perspective they’re still going to trigger the same SGT upgrades. So, some parties would benefit from this, some parties it would make no difference.

00:28:57 – Hugh Taylor
Okay, cool, that’s very interesting kind of nuance. So, if you are looking at having, if you are somebody who has a great diversity across the whole country at distribution, it’s not necessarily going to be clear as to whether or not you would be penalised by the current suggested approach. I had a, sorry, go on.

00:29:23 – Catherine Cleary
I was going to say, I guess, yes. So, there’s an argument which says, well, there’s a lot of people this won’t benefit and it’s more complicated. So perhaps Hugh I mean I didn’t say that in my opening statement, but that’s probably what you were expecting me to say, is it’s just really hard to do this because we’d be asking NESO to reorder the queue based on dates they don’t have – so there’s a data transparency issue. You know, effectively we’d be saying, right, well, there needs to be some kind of fair way of the DNOs or making sure that they transparently pass across queue positions to NESO, which is, and NESO would then have to start caring about what those relevant distribution, individual specific distribution projects, queue dates were – which they don’t currently. So there’s a kind of like data issue and also the..

00:30:07 – Hugh Taylor
I’ll tell you what, if I could just say it was my understanding, which is often wrong, that under the sort of ENA best practice guidance around interactivity at distribution and transmission, that those dates, the application date, should have been passed up the chain to the ESO and, as was, and the ESO should have been taking that into account in terms of interactivity with transmission projects, have I got that wrong?

00:30:35 – Catherine Cleary
No, but it’s a really, it’s complicated Hugh because, if you, so, the interactivity process is the reason we can use offer acceptance dates as queue positions. It’s because you might say, well, hang on a moment, what if someone applied first but then accepted second? But if they had an impact on each other, those two projects would get made interactive and therefore, the new interactivity process means that it’s conditional, only project one can accept, unless project one doesn’t accept; and then projects two, three or four can accept. So yes, you’ll be right. For interactivity purposes, when determining who should be first in an interactive queue, it’s application date that matters. But if you are not interactive, and once you’ve become interactive and they’ve done that queue positioning based on your application date, then it’s just who signs first.

00:31:21 – Hugh Taylor
Okay, in terms of data. So Pete, the ECR, so the embedded capacity registers that each of the DNOs has and publishes and updates monthly and some of them are maybe less accurate than others. At the moment I don’t think that on there there’s the distribution acceptance date, and I don’t think there’s the PP submission, the project progression submission date, what part they’re in an appendix G – all of that?

0:31:44 – Pete Aston
So on the ECR you have…

00:31:44 – Catherine Cleary
Date accepted?

00:31:45 – Pete Aston
Yeah, date of acceptance and sort of proposed connection date. So most of the ECRs from most of the DNOs have got the acceptance date of a scheme that’s accepted to connect but not yet connected. Some of the DNOs have populated a sort of proposed connection date field. One of the DNOs, which will remain nameless, that I looked at yesterday has ‘to be confirmed’ for every one except two sites I noticed. I don’t know why those two sites sneaked in with a connection date.

Um, and I think, interestingly, that’s probably impacted on NESO’s data impact assessment graphs that maybe we’re going to now. But, some of those graphs showing the different, the size of the pots and so on, have probably been quite significantly impacted by some dodgy data within the ECRs. But yeah, in terms of project progression dates and so on, I think that’s much less visible. Some of the DNOs are publishing Appendix G data and so on. So for some of the DNOs you can see a list of schemes and which part in the Appendix G it’s in and, like NGED for example, on their Clearview platform, if you type in your project reference number, you can then see where you are in the queue and see how many schemes are ahead of you in the queue. So there is some data out there, but it’s not that clear. I don’t think you’d be able to sort of do what you were suggesting and look at all of the project progression, submission dates and acceptance dates and see where you all lined up

00:33:15 – Hugh Taylor
Yeah, so it’s interesting. Yesterday Tom Palmer on LinkedIn said why don’t we have a sort of a combined ECR, TEC register and the Renewable Energy Planning Database (REPD) kind of all combined into one, which I think would be very hard to achieve, but it would be very useful. But actually, wouldn’t it be really useful if you could see the date that the project progression was submitted, the date that it was accepted, and so that you can actually see.. Because I don’t think any of us really, none of us know what the impact of either of these decisions is going to be. We can’t empirically say how many megawatts are going to be disadvantaged or advantaged. I think none of the, probably none of the, DNOs are going to put their hand up to putting the date that they submitted that project progression on the ECR, because you know it’s going to be a car crash, isn’t it? It’s going to be a car crash, isn’t it?

00:34:18 – Pete Aston
I don’t think it would go on the ECR anyway, because the ECRs are sort of, you know, got a fixed format and so on, but it could potentially go somewhere else on a DNO website. But I think it would be. Yeah, I think you’re right, it’s. It’s probably not very easy for them to do. And sort of which date do you do? Provide the date you’ve submitted it, or the date that you first got the mod offer back, or the date when you signed it, or however many arguments you had between the DNO and NESO about all the data.

00:34:18 – Catherine Cleary
I think if we want to be really pedantic, then we could say that actually this data should possibly actually already be being published under the CUSC because there is something called an embedded capacity register. So we all talk about the TEC register, which is Transmission Entry Capacity. But NESO also publish an embedded capacity register, which, if anyone’s ever looked at it, you know, is effectively people with things like BELLA agreements in Scotland. And technically, the embedded capacity register should cover relevant embedded generators, and relevant embedded generators is now, you know, pretty much everyone at a megawatt and above. So there is an argument that says actually some of this data should already be being published by NESO.
I think just to, I don’t know if we’re going to swap, but I can definitely rebut some of my own points probably.

00:35:26 – Pete Aston
I want to say a few points from the other side now!

00:35: 27 – Hugh Taylor
I know that Pete’s got a call quite soon as well. So go!

00:35:36 – Catherine Cleary
I’ve got to join CPAG in 13 minutes!

So. I would say, right, well, we’re saying this is hard and also that there might be kind of like winners and losers in that queue position issue, and you know you’re kind of reducing certainty. But actually you know it being hard is it’s already really hard. What we’re proposing to do, that intercalation of projects, is already really tricky and is going to effectively almost be a kind of semi-manual exercise.

The one thing we have as published data, as you’ve said Hugh, on the ECR, is distribution projects accepted dates, and so you know, actually this is not beyond the wit of man. We already have the data and it’s in the public domain, which is actually much easier than the project progression data, which is not in the public domain. And therefore, there’s a question about data transparency, fairness, you know, can anyone scrutinize that queue position process? So you could argue, this alternative proposal is no harder to implement than what NESO are currently proposing to implement, because there already needs to be that kind of intercalation of the queues. The date that you use, you know, I would argue, should be a published date that everyone can interrogate, so that there is transparency and that we can be like, because with any data processing issues, you know that the outcome will only be as good as the data that we have and therefore there needs to be a way for us as an industry to be able to kind of robustly challenge that if we think it’s gone wrong.

00:36:46 – Hugh Taylor
Right, thanks, Pete?

00:36:48 – Pete Aston
Yeah, I think there’s just a point here that there is already nuance within the DNOs in terms of connection dates and so on. So forget transmission access for a minute. If you’re just looking at a DNO connection queue, obviously you’ve got the application date order, which is the order in which you were treated in terms of designing your connection order, but in terms of the date you actually get connected, that comes down to a certain extent to how quickly individual projects progress. So it’s quite possible for a scheme that has a later application date, so it’s sort of further down the queue, as it were, to get connected first because they’ve just got ready quicker, maybe it’s a smaller project, easier to progress, and so the DNOs end up allocating some resource to that particular project to start with, and then they’ll go back to the project that was earlier in the queue just because they didn’t come along so quickly and get their project developed so quickly and then build them second. So there’s already a sense in which some projects get connected before others within the DNO.

00:37:57 – Catherine Cleary
Queue position doesn’t correlate with connection date. Iit doesn’t know transmission either. So queue position is really I guess what we’re saying is you know, if you’re talking about the same project, it’s a project underneath the same GSP then queue position would correlate with, for example, the scope of reinforcement works you’re triggering…

00:37: 57 – Hugh Taylor
I don’t know whether we might have just lost Catherine…! Go, go, go Pete!

00:38:17 – Pete Aston
I think there’s another point, this is debatable. I’m debating it even with myself! It’s just that I wondered, I think I said this to the other team yesterday and they sort of slightly shut me down, but in a sense of, if you are a solar, if you’re anything other than battery as a distribution connection, there is a good chance that there’s going to be a, that you’re going to get connected just because of the size of the pots. I think there’s quite a lot of issue with the data, within the data impact assessment and so on, and I appreciate there’s lots of nuances around that.

But, it’s clearly that the biggest impact is going to be on batteries. Because there’s so many in the queue and it’s you know, how has that allocation of batteries happened across all the different transmission and DNO areas, and how has that capacity been split between transmission and distribution? So some of this is not just about what is your queue order. It’s how have those pots been allocated, especially for battery schemes, where we know there’s far more batteries than there are pots to put the batteries in?

00:39:30 – Hugh Taylor
Yeah, and I think that’s a very big question and one I didn’t particularly want to go into, and that is sort of the data that NESO has used and how they’ve applied that data, you know, I think that’s a whole sort of another – it’s a very good question.

00:39:48 – Pete Aston
It is, but it’s also a question of, we could debate this issue of should it be DNO application date or project progression date to the minutiae, and then find it’s the size of the pot that’s made the biggest difference as opposed to your queue position?

00:39:53 – Hugh Taylor
Yeah.

00:39:55 – Pete Aston
So these, these are all interrelated.

00:39:58 – Hugh Taylor
I would quite like to, just of either of you. I don’t know whether we might have lost Catherine, but if either of you could just speak to how hard this would be, is it too hard? So Catherine just said we’ve got the distribution acceptance date in the DECRs, so we’ve got a date, but actually how hard would it be to use that date?

00:40:33 – Catherine Cleary
I don’t think it’s very hard. Can you hear me?

00:40:34 – Hugh Taylor
Yeah, we’ve got you, thanks.

00:40:37 – Catherine Cleary
So I don’t think it’s necessarily any harder from an administrative perspective to work out the relative queue positions using that date. What is harder is that because we are now more likely to be changing the relative queue positions of, for example, transmission projects and I might now have some embedded projects that have come ahead of them in the queue, there will be more reassessment work of the technical works required to the power system studies. More work will be required by the TOs to work out right, okay, now my transmission project, which is progressing, you know, and is needed and ready, and before I could have just said, great, well, they only have their scope of enabling works, reinforcement works, or can I take any of those reinforcement works out? Now they’re going to have to think actually, are there any reinforcement works I have to add back in because they’ve been leapfrogged by some embedded projects.
So my biggest risk, I think about this, is actually in the implementation of it is that we’ve currently got a kind of six month window you know, possibly shorter than six months window, where the TOs next year are going to try and reassess every project in the queue and they’re going to do that quite strategically by basically trying to prioritise those projects in the CP30 queue and, as I say, it’s almost like a kind of half assessment, just like looking for improvement opportunities. If we were to introduce this change, they have to do a full reassessment. My concern would be that that moves from being a four, five, six month process into an 18 month process. You know, I think we could be looking at huge levels of resource required to actually potentially implement those changes

00:42:07 – Pete Aston
And if you think about, things like technical limits as well – technical limits is based on project progression dates. So it unravels the technical limit dates that have been provided, technical limit levels that have been provided and all sorts of different things.

00:42:22 – Catherine Cleary
It would change who is securitizing and triggering which capital works as well. So I think there’s an element there where there’s a kind of argument which says, well, hang on a minute. Projects that have made investment decisions or have said, yes, we accept this level of liability. If you start rejuggling that round are you just causing a lot of investment uncertainty?

00:42:29 – Hugh Taylor
OK, well, so we could be potentially looking at really quite significant delays if we went down this route. The investment decisions that people have been making based on their technical limits offers that they’ve got, they would essentially have to be torn up after the event anyway, because the curtailment limits are going to be completely different. Would that be right?

00:42:58 – Pete Aston
Yes, but I would suggest that it feels likely that your technical limits would improve if, as a DNO customer, you’re based on your application date, because almost certainly that’s going to be earlier in the queue than your project progression date. I think, so as a DNO customer, it’s probably going to get better, you know, if you did that, but again, it’s just the complexity of the unpicking of it all would be would be highly complex, because the setting of the technical limits level was based on you know what was in part two of Appendix G at the time they set technical limits and that just gets ripped up. Essentially, so lots of change.

00:43:40 – Pete Aston
So is it so complex that we could be looking at literally an additional year of delay to getting to Clean Power by 2031?

00:43:52 – Catherine Cleary
I think the honest answer is that the TOs probably need to be consulted on both options. How long is it actually going to take them to reassess the queue? And there are a couple of different scenarios for doing that reassessment, and I think you know we need some clear, transparent industry feedback as to how long it’s realistically going to take. I’m not convinced that we necessarily have a huge amount of confidence that the current proposal is doable within that four to five months, you know. So I think there are probably some realistic questions about how long it takes to any of this. So that in itself is perhaps not a reason to shut this down as an option, but it is a reason to say do we need some more assessment of the options?

I realize that’s probably everyone’s had enough of assessment of options. They just want to do things now, but this is quite, you know, we won’t have another opportunity to do this, so this is a one-off opportunity to kind of right that wrong that, as Pete said at the beginning, you know a lot of people do perceive this to be a huge kind of you know well, morally, ethically dubious, you know, situation that we’ve got ourselves into, and this is a kind of one-off opportunity to do that. So I suppose that the kind of critical question is we can’t just say it’s a bit hard. So actually, do we need to evidence why it’s too hard? I think the only parties that can really do that would be TOs who say we think this would increase the magnitude of study work by this kind of quantum.

00:45:12 – Hugh Taylor
Pete?

00:45:15 – Pete Aston
No, I’ve got nothing else. I’ve scraped the barrel

00:45:19 – Hugh Taylor
Well, you’ve, each of you got three minutes until your next call. So, I just yeah, I mean, I must say I was expecting to get to the end of it and have a clear position one way or the other. I simply don’t! It’s actually far more complicated and nuanced than even I’d imagined. Um, so I actually felt like I want to… It’s like Pete said on a podcast that I don’t know if it’s gone out yet. He said the other day that connections reform is like an onion there’s loads of layers and when you start peeling them off it’s going to make you cry, and that’s exactly the way I feel about it right now.

But thank you so much. Hopefully that has helped with the context. I think there’s going to be a lot of debate. That debate, hopefully it can continue, probably on LinkedIn. We’ll publish this and then maybe do a poll, which would be really cool. We’ve never done a poll on LinkedIn. This might be a good time to do it, but then randoms who don’t even know what a grid is might join in, which would be a shame. But thank you so much, both of you, thank you everybody for listening. This has been a very long one, and it’s been quite nuanced. We hope it’s been useful to you. So thank you and see you again very soon.