June Connections Reform Consultation 

July, 2023 - Shoosmiths LLP

"Leave this to me, I'm British… I know how to queue."{1}

The Energy Services Operator (ESO) recently published a consultation which sets out a vision of medium-term reform for connections to (or affecting) the Transmission Network, whether they are directly connected or embedded.

The consultation forms part of a wider tapestry of electricity network reform, following the publication of the ESO's Five-Point Plan{2} for reducing short-term capacity constraints in grid connections, and all standing in the shadow of the ongoing Review of Electricity Markets Arrangements (REMA), which continues apace.

Notably, the ESO's preferred set of reforms are the most radical of the four options which the ESO has consulted on with stakeholders to date. 

The process which the ESO proposes looks like this:

  • Connection applications would be made in set application windows (assumed to be annual), known as "Gate 1" and a departure from the current position that generators can apply for a connection year-round; 
  • Gate 1 applications would be reviewed in bulk (applying the most recent data around attrition values for grid connections) to aid in overall system design; and
  • Individual Projects would only get a place in the queue once their project meets other significant milestones – most notably, submission of planning consents ("Gate 2").

This moves the queueing system for transmission network connections from "first come first served" (as under the current model) to "first ready, first served", as even access to Gate 1 depends on being able to produce an, as yet undefined, Letter of Authority. The ESO also recommends allowing well-developed or other "priority" projects to jump ahead when capacity drops out of the queue (termed "Reactive Queue Management Plus" in the consultation). 

Practically speaking, this means developers can expect to wait longer for their firm date to connect, but the date they receive should ultimately be sooner than before.

Energy & infrastructure partner Chris Pritchett has recently produced key takeaways from the recent UK Solar Summit, where availability and speed of grid connections was top of the agenda.

Who will benefit the most under the proposed changes?

Whether the consultation represents positive or negative news for developers looking to connect depends to a large extent on the momentum and readiness of the projects in their portfolio:

  • Generators who have the finance in place to move fast and progress their projects quickly now have a real chance of seeing their projects offered an earlier grid connection date;
  • Consented projects who are languishing in the queue behind a number of less progressed or speculative projects which may never come to fruition will be prime candidates to find themselves managed to near the front of the queue
  • Combined with the implementation of the five-point plan, the end of stringent connection assumptions for energy storage projects look to be the big winners from the reforms so far. Expect to see connections these projects accelerated ("turbo-charged"?) in the medium term.

But the news isn't good for every developer:

  • Early-stage illiquid developers who lack the resources to fund the planning stage of projects may find external funding harder to secure, at least in the short term until the process is more understood;
  • Those who pre-package projects consisting of pre-consented land and grid connections as a means of selling projects pre-consent no longer have the benefit of an early firm connection date as part of that package.

What's clear is that this reform will change how grid connections are looked at in the project cycle, and it will be fascinating to see (and challenging to anticipate) what impacts this will have. For example:

  • We can expect to see developers begin to lose their place in the queue, with potentially critical impacts on their project. Expect a rise in legal challenges, certainly from developers who lose their place, but also potentially from those who feel aggrieved at the decision to accelerate a rival project in preference to their own.
  • The changes in the process means that projects will wait longer for a firm date to connect, but overall dates for connection should contract. How will this affect the project pipeline, particularly in relation to the timing (and conditions surrounding) receipt of finance? 
  • How will the Gate 1 access requirements balance the ESO's need for applications which reflect a genuine forecast of future connection needs with a developer's need to ensure their projects are in the hat for a connection date?
  • The focus on future-proofing the process is interesting and leaves the door open to particular technologies or geographies being given preferential treatment in the queue. This is a great lever to have available to kick-start development in a sector or region, or both. Giving hydrogen electrolysers up in Scotland priority passes to help soak up some of the excess generation and reduce curtailment, for example.

What's next?

The consultation remains open until 28 July and seeks comments on all areas of the ESO's proposals. If you would like to discuss your response with one of clean energy team, or just to understand in more detail what the proposed reforms could mean for you, please don't hesitate to get in touch. 

 

 

Resources

  1. Arthur Dent in The Hitchhiker's Guide to the Galaxy, 2005
  2. What are we doing now? Our five point plan ESO (nationalgrideso.com)

 



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