00:00:32 – Kyle Murchie
Hello and welcome to another Connectology® podcast with myself, Kyle Murchie and my colleague, Pete Aston.

00:00:39 – Pete Aston
Hello.

00:00:40 – Kyle Murchie
Now, we weren’t planning to do a Grid News and Views today, but given that this week has been a lot in the news from a connections perspective, we thought we would touch on two topics relatively briefly that will pick up further in due course – the first one being CMP446, the change in the TIA threshold, and the other being queue management, more specifically the ENA queue management milestones. So, first of all Pete, on CMP446, what’s the news?

00:01:10 – Pete Aston
If I can remember, after having done four podcasts already and a roundtable discussion, brains are slightly sort of zapped, I think today and the room is very hot. But that aside, so CMP446, like you said, was there to raise the TIA threshold in England and Wales from one megawatt to five megawatts. So, the generation schemes that are less than five megawatts don’t need to go through the TIA process and therefore don’t have any transmission impact – so really positive change.

So, the working group finished, I think in March, and there were two main options that it was going to proceed with. So, the original proposal was for the TIA threshold to be set at five megawatts of registered capacity, so effectively an installed capacity level. So better than what’s there now, and certainly gives consistency because at the moment the DNO was applied the one-megawatt level; some said export capacity, some said installed capacity, so it was a bit of a hit and miss approach across the country, so that would have at least given some certainty. There was another proposal WACM raised which is to do it based on export capacity, which would give a lot more flexibility for sites that are trying to decarbonise.

So, long story short, Ofgem came up with a decision, I think it was yesterday or the day before the 12th of May, and decided that they yesterday were going to prove it and they were going to approve WACM 1, which is basing on export capacity. So, I believe that the CUSC change has now been implemented as of today I think so theoretically, as of today, schemes that are less than five megawatts. So, I think that due to the rounding in CUSC, I think this is 4.94 megawatts or below effectively of export capacity effectively no longer needs to go through a TIA. There is an exception for transmission, so grid supply points where there is less than 1kA fault level headroom.

00:03:36 – Kyle Murchie
Right, okay.

00:03:37 – Pete Aston
So, on those sites the threshold is still 1 megawatt and maybe a little bit of murkiness around that. So, to scheme less than 1 megawatt with a high fault in feed to still get prevented from connecting.

00:03:30 – Kyle Murchie
And that one megawatt is that, so if that is one megawatt, is that one megawatt of export capacity, install capacity, what’s that figure based on?

00:03:55 – Pete Aston
I can’t quite remember. I’d have to go and read exactly what the thing said and I’m not quite sure whether it was one megawatt based on the previous woolly one megawatt or the, you know, a newly defined one megawatt. So yeah, we probably need to look at that a bit more carefully. But yeah, sites where there’s a fault level constraint there will still be a transmission impact and I think from memory there were sort of 15 to 20 sites something like that in the original documentation published, that could be problematic.

00:04:39 – Kyle Murchie
So, it’s not significant, but in the grand scheme of things, a lot of projects are going to be able to move forward more quickly. So, for example, if you had a 7 megawatts of install capacity but you were never going to be exporting more than 4 megawatts, let’s say, because you’ve got quite a high demand, then you wouldn’t need to go through a transmission impact assessment. Is that right?

00:04:57 – Pete Aston
Correct, and so this is both retrospective and forward-looking. So, theoretically, any schemes that are out there that are already less than 5 megawatts of export capacity should at some point get a variation of some kind from the DNO to say that you no longer need a transmission impact assessment. So, I guess the schemes will be in a couple of different positions, some of them, so if it’s got an accepted offer, some of them will have already been through a TIA, some may not if they’re more recent. So not quite sure how the DNOs are going to unpick that, but there’ll be some sorts of variation process because what they want to do is make sure that those schemes don’t go through the Gate 2 to the whole queue process; because that’s one of the reasons for Ofgem approving this, is so that it cuts down the amount of administration work for NESO and the DNOs. So, I’m assuming that they’re going to have to do those letters within the next month.

00:06:00 – Kyle Murchie
Yeah, timing has been very important, but I think the messaging as well, because there will be projects out there where they have now just understood what they need to do from a Connections Reform perspective and now finding that actually they may be exempt from the transmission impact assessment aspect. So, I think it’s quite an important message, particularly for those parties where, you know, it might be a community energy scheme or a relatively small development co-located with demand. So yeah, really interesting.

00:06:32 – Pete Aston
So, yeah, I think it’s very positive for quite a lot of schemes, I think this one, yeah. So, there should be a lot of customers out there who get some real benefit from this one.

00:06:45 – Kyle Murchie
Great.

The other topic we wanted to touch on, and I think it’s a nice comparison where you know it was a fairly complicated subject, and noting as well probably worth kind of highlighting again that it is applicable to England and Wales, not to the threshold in Scotland which sticks at the 200 kilowatts. So that obviously will be progressed separately. But there has been a working group a lot …

00:07:14 – Pete Aston
Of full on CUSC working group.

00:06:55 – Kyle Murchie
And can you remember, I know you’ve been sitting on it, how long has it been running for?

00:07:20 – Pete Aston
Oh, it maybe run for a couple of months because it got urgency. You know pretty intense group of meetings to pull together everything, but yeah, so it concluded pretty quickly.

00:07:36 – Kyle Murchie
But in that process, you had all the views of the networks, you had the view of NESO, were able to get feedback and kind of thinking going on as part of a wider group of industry participants to come to a pretty solid solution. Irrespective of whether you agreed or disagreed and voted for or against, at least it has gone through a good formal process.

I think the other topic queue management and the ENA queue management milestones similar sort of situation you could argue, where there is quite a lot to cover. I think it’s interesting because you could see on the face of it that the intention is to effectively align those queue management milestones that the ENA have for distribution customers with transmission.

The transmission queue management milestones have been developed through CMP 376. And then more recently through Connection Reform, they’ve brought in that split between forward-looking milestones and backward-looking milestones, and I think applying that regime to distribution projects at a high level makes sense. A lot of people agree that there’s a sense both to try and have alignment. But that’s very much been developed by the DNOs and the ENA, I think just since we’ve had a couple of engagements with the NESO seminar back in March. I think it was where there was initial conversation around changes to the milestone rules and more recently this month, we’ve had the webinar that the ENA hosted. And, let’s just say, our e-mail inbox is definitely lit up quite a bit. A lot of feedback, I suppose just general concern around what is the change, what’s been proposed, but also basically what is the right approach.

00:09:30 – Pete Aston
I think there was some concerns around visibility of how the change to these milestones is being developed, because if you didn’t happen to have been at the NESO seminar, which was a face-to-face event in Edinburgh, was it?

00:09:46 – Kyle Murchie
Yeah, that’s right.

00:09:47 – Pete Aston
And if you didn’t happen to get to the ENA’s webinar last week, I think it was, then you know you wouldn’t know about this, apart from you know seeing stuff on LinkedIn or whatever. So I think you know it’s maybe a relatively small pool of sort of industry participants who’ve seen what’s going on, and then it’s just the questions, the ENA just put questions in basically the slide pack that they had from the webinar as to say here’s some questions, we want to hear your responses, rather than sort of a formalised consultation-type process where documentation is emailed out and so on.

00:10:38 – Kyle Murchie
Yeah, absolutely. I think we’ve got the first layer of general industry engagement from a wider perspective, which you would get as a working group, isn’t there. Followed by formal consultation. Because while there’s, as you say, an invite to respond to an email inbox, there’s also no format specifically, it’s here’s some initial questions based on the back of the slides. We’re not consulting, so to speak, on the guidance itself, a draft version. It is a set of slides and some ideas, followed by examples, and the time frame is really short as well. You know we’re talking about the 23rd of May, which, when this goes out, we’ll be possibly very close to that time frame, but you know, even as we, following that webinar, that’s effectively a couple of weeks,

00:11:28 – Pete Aston
About two weeks.

00:11:29 – Kyle Murchie
Which is short for any consultation.

00:11:32 – Pete Aston
Yeah, it is. I wonder whether it’s not the timescale so much, as just the way the information is being presented or whatever, that’s problematic. Because some of the consultations that have come out recently, some of them have had pretty tight turnaround. Maybe people in the industry are sort of getting used to that.

00:11:56 – Kyle Murchie
Yeah, absolutely, and I think, while again the concept of aligning with transmission in theory at a high level sounds appropriate, it’s then, once you get into the detail of what is remaining from the existing milestones, if you’re not changing that two-month period, for example, between accepting and then initiating planning, if that’s effectively been applied going forward, where you accept your Gate 2 offer now and then have to initiate planning within two months. Have you ever seen a project this?

00:12:30 – Pete Aston
Yeah, I think. I think this is because the ENA slides say, you know, they’re only changing certain things and they’re not changing that two-month period for getting planning. They’re just saying it’s got to be done from your Gate 2 offer coming through fine, but I’m not sure I’m aware of any project that’s ever met that two-month planning milestone from accepting the, you know, the DNO offer and that it seems to me like all the DNOs have just gone. Yeah, that can never happen, so we’re never really going to chase that one down very hard. So, I think the danger is of they’re not, you know, almost keeping that as it is, is what’s the unintended consequence if you know, schemes that go through Connections Reform, are they then going to get kicked out the queue because they don’t have planning? And so, we were talking just before we started the podcast that, if you’ve got a protection, yeah, and quite a lot of the protections will be based on either being connected by the end of 2026. So, you’ll have planning ready or you’re protected because you’ve got planning. Yeah, you know, that’s a tick in the box already, but there’s still quite a few schemes out there that are going to go through Connections Reform and won’t have got planning. And what’s going to happen to those schemes, are they just literally going to accept their Gate 2 offer and two months later just get kicked out the queue?

00:13:51 – Kyle Murchie
Yes, we should say that you know the existing process of and tolerance is effectively going. So, you can argue at the moment that let me say there’s a lot of flexibility around that two months doesn’t necessarily happen, but also you’ve got a tolerance regime anyway where you don’t necessarily, if you’ve missed that date, it’s just counting. You know they’re kind of eating away at your tolerance. What if we’re moving away from that and going to a kind of remedy sort of situation where you have a fixed milestone and then so many working days in which to rectify the situation? Then that is a completely different approach, because you know have to really stick to that.

00:14:27 – Pete Aston
And you explain to me what remedy actually means, because I got it wrong.

00:14:31 – Kyle Murchie
So, the remedy is to effectively remedy the situation where you don’t have the evidence, so you can provide the evidence after that date, but the evidence has to say that you’ve met the milestone effectively.

00:14:45 – Pete Aston
So basically, it is a hard stop. If you don’t meet that two-month submit planning milestone, theoretically you are out.

00:14:53 – Kyle Murchie
It was a window in which you couldn’t automatically terminate on that date without giving people the opportunity to provide the evidence.

00:14:35 – Pete Aston
But now the DNOs will be able to automatically terminate schemes after maybe waiting 60 days for the developer to say no, I actually didn’t get planning within that time period, and then they’re out. And I think that’s really challenging, I think.

00:15:00 – Kyle Murchie
And I think an unintended consequence of taking two regimes and not going through. There have been some examples and it’s good to see examples being thought through, but you have to have that wider visibility and wider group of individuals kind of feeding into development of solution.

00:15:35 – Pete Aston
Don’t get me wrong, because I’m all for developers needing milestones, and you know, have pushing projects forward. But it was just that that two-month submit planning milestone is just so unachievable.

00:15:35 – Kyle Murchie
But then also, one of the you know we’ve been talking about, once you do have planning. So once planning is granted, we’ve then got six months in which to have your ICP design submission, assuming that you’re going down the route of POCO only, so that again, we were talking about earlier that six-month period. You have to have already initiated that before you have planning in place.

So, I think there’s that question of if you take away the tolerance and you apply the remedy approach to effectively the existing dates, or a very subtle variation of them. It’s whether that’s really fit for purpose and whether projects can meet those. Because I suppose with transmission milestones the intention was to be relatively you know those milestones were not to be breached the world that we have been in with distribution milestones.

00:16:40 – Pete Aston
As you’re saying, we have been breached all the time. You know it comes down to the DNO engineers and connections teams going – you know, okay, I can see you’re making some progress, let’s be a little bit softly softly, but this almost takes that option away from the DNOs. They almost have to be very strict about it, even if they wanted to be a bit softly, maybe the DNOs will like it, I don’t know. It does mean that the DNOs then have to actually follow these up as well, and that’s quite hard.

00:17:18 – Kyle Murchie
So we’re not going to solve the solution today and that’s not the aim, and it’s first of all flagging that you know by the 23rd of May, please do make submissions. We’ll put a link alongside this podcast to the slides.

00:17:32 – Pete Aston
Which are difficult to find.

00:17:34 – Kyle Murchie
Which are quite difficult to find. Yes, it did take a bit of effort and actually had to get them from the ENA directly. So, we will definitely share that and please do respond. But the wider ask of the ENA effectively is look, let’s not rush into this, you know, there is time. They’re going to be applied retrospectively anyway, so it doesn’t really matter if it’s done by the beginning of June, or sorry as beginning of July as intended. Why not have a working group, have a bit more input and get the right solution or something more informed solution could end up being the same place if that’s what the group comes to. But I think that would satisfy a lot of the stakeholders and remove a lot of the concern.

Thank you very much for listening. See you in the next one.

00:18:23 – Pete Aston
See you.