In October 2022, NGESO (National Grid Electricity System Operator) launched a connection reform project. It is now running an industry consultation on the proposed reforms, seeking views on their modification proposals CMP434 & CMP435.
These proposals seek to introduce;
- a new process for securing capacity on the Transmission Network for users wishing to connect either directly to the Transmission Network or to the Distribution Network as an ‘embedded’ user (CMP434) and
- to retrospectively apply this process to all existing applicants (CMP435).
One of the major issues currently experienced in the industry is the very long delays to the connection of renewable energy schemes. These delays are in most cases due to the Transmission Network upgrade works deemed necessary to accommodate these schemes.
In our response to the consultation, Ethical Power will:
- express support for elements of the proposals in general,
- agree that an annual batched assessment of applications to allow a holistic view of the demand for connections is necessary
- agree that a ‘Gate’ system, which allows schemes that are making progress to be given an earlier connection date, will apply the crucial reform the industry requires.
We will also provide comments where we feel the proposals do not go far enough or do not address issues at all.
Jumping the queue?
The lack of reform to the interface between Transmission and Distribution companies is our primary concern. This interface has long been a challenge and the existing Statement of Works, Project Progression and Modification Application processes are long overdue reform. The process of getting connected to the Transmission Network has been prioritised over the Distribution Network, and in our view has thus ‘jumped the queue’.
The current proposals suggest that Distribution Network Operators will provide National Grid with a forecast of how much capacity they will need for new connection applications. This is still dependent on the Statement of Works, Project Progression and Modification Application processes to secure capacity for Distribution-connected users once they have made sufficient progress.
Our concerns include;
- Can DNOs accurately forecast demand for connections? They may be tempted to ask for very high volumes to avoid the risk of exceeding their forecast, thus producing unnecessarily onerous estimates for Transmission works, and later connection dates than needed.
- Could DNO users be disadvantaged due to the time taken to go through the Statement of Works process to reach Gate 2 while Transmission customers can ‘self-certify’?
Much more consideration needs to be given to how we can have a process that does not favour either Transmission or Distribution applicants and does not introduce steps that are prone to long delays, or at least adds measures such as guaranteed standards of performance that penalise any delays.
Perhaps it is telling that, while the current reforms are intended to be concluded within 30 months from start to finish, a previous attempt to improve the Transmission and Distribution interface* took 8 years to complete without producing an enduring improvement to the process.
The Transmission and Distribution interface may be even more difficult to solve, and we are concerned that these code modifications are being prioritised over the existing delays to many Distribution-scale schemes ready to connect.
We agree that reforms are needed, but as there are already many Distribution scale schemes ready to connect, and they will certainly be needed in order for GB to meet its Net Zero targets, these code modifications should not be implemented until this is addressed. Ethical Power will be responding to the consultation expressing these concerns and urges all affected parties to read and respond to the consultation.
Responding to the consultation
The consultation opened on the 25th of July and closes on the 6th of August at 5 pm.
To access the consultation documents, including the response proformas you may use the below links;
CMP434 Implementing Connections Reform | ESO (nationalgrideso.com)
CMP435 Application of Gate 2 Criteria to existing contracted background | ESO (nationalgrideso.com)
* CMP298: Updating the Statement of Works process to facilitate aggregated assessment of relevant and collectively relevant embedded generation modification was raised in April 2018 with a final decision made by the authority on 4th January 2024.