Energy UK response to Consultation on the proposed regulatory funding and approval framework for onshore transitional Centralised Strategic Network Plan 2 projects

Executive Summary

Energy UK welcomes Ofgem’s consultation on the funding an approval process for the
identified tCSNP2 projects. We overall agree with the proposals and appreciate the level of ambition Ofgem is showing in order to achieve the UK’s decarbonisation targets and obligations. We also do agree with the need to further optioneer the majority of the identified projects given their immaturity and we agree with the proposed track processes.

We note concerns from members on the hesitancy Ofgem feels in some areas, especially regarding the accuracy of the FES’ assumed deployment of offshore wind in 2035. Anticipatory investment by its nature implies accepting a higher degree of uncertainty of future generation mix in order to ensure network is delivered in a timely fashion. While it is sensible for Ofgem to acknowledge the uncertainties outlined in the consultation we strongly advice Ofgem not to err too much on the side of caution and consider the cost of late delivery or non-delivery of tCSNP2 projects.

We also encourage Ofgem to ensure that coordination and synergies with the ongoing ASTI projects are enabled and that there is sufficient adaptability of projects to the upcoming Clean Power by 2030 (CP2030) plan. There is also a need to account for coordination with REMA and network charging reform. Most importantly, the form of tCSNP2 projects should also account for the rapidly changing arrangements to
connections processes and the uncertainty for industry investment that has subsequently emerged.

Finally, we ask whether there is an opportunity to integrate this large scale workstream with a wider Government industrial sector deal. Some in the industry are already aware that Great British Energy (GBE) is exploring what role it might play in securing the supply chain for the energy transition as well as the needed labour force. Whatever form such a project might take, the potential synergy with tCSNP2 projects moving into the Development track might present a substantial opportunity for economic growth, job creation, energy bill reduction as well as decarbonisation. This could serve as an opportunity for the UK to cement itself as a world leader in the energy transition and an exemplar to other countries.

For further enquiries please contact:

Tobias Burke
Policy Manager
Tobias.Burke@energy-uk.org.uk