Citizens Advice response to Ofgem Consultation on the initial findings of our Electricity Transmission Network Planning Review
The growth in offshore renewables and the increased provision of system flexibility to support decarbonisation should be at an efficient cost for consumers. The ETNPR is an important addition to the OTNR in pursuing this objective because it can support the efficient utilisation of offshore wind in the energy system to support Net Zero through strategic investment. It should align network development in both the transitional and enduring onshore regimes with equivalent programmes offshore, to enable a consistent process of energy system development.
The ETNPR should, specifically in the short term transitional arrangements and early stages of the enduring model, ensure that coordinated network design facilitates time-sensitive low-risk strategic investment in transmission. Well-informed models of centralised network design, led by Ofgem, the Future System Operator and supported by electricity transmission networks, should work to encourage consistency, transparency and confidence in the direction of strategic investment (SI) to minimise unnecessary investment risk and therefore efficient cost.
For the longer-term enduring regime, this arrangement, even with the form of early competition outlined in the Centralised Strategic Network Plan (CSNP), will likely struggle to harness the potential of collaboration between different energy networks and with network and non-network assets. There is limited scope for collaboration given the narrow ‘investment options’ window for input from Electricity Transmission Operators (TOs) and third parties. This will lead to inefficient network costs. It creates a process that will be highly reliant on the FSO for coming up with the ‘right answer’ for strategic and coordinated investment arrangements.
We think it is important when establishing the FSO and the ETNPR that the long term objective is to establish a development process that will effectively incentivise and harness innovation in network design.