Energy UK response to Reformed National Pricing (RNP) Delivery Plan consultation 

Executive Summary

Energy UK welcomes the publication of the Reformed National Pricing (RNP) Delivery Plan, which provides much needed clarity on the overall strategic direction of the RNP programme. We welcome the increased certainty provided as prolonged ambiguity undermines delivery and investment.

It is positive to see the Government set out how it intends to align reforms to deliver the Strategic Spatial Energy Plan (SSEP), and we welcome the opportunity to respond to the consultation questions on Siting and Investment Levers within the Delivery Plan. Energy UK broadly agrees with the approach taken in the Delivery Plan to combine the different locational investment levers into an options framework.

Energy UK is supportive of the Government’s minded-to decision to take forward Options 2a, 2b and 3 for further consideration. At this stage, more detail and further engagement are required before Energy UK can support a particular option.

Option 3 reflects a strong approach for maintaining competition, which is important for driving efficient and least-cost outcomes for consumers. Under this option, it will be particularly important to set the Connections Capacity Threshold (CCT) above the planning line to allow for sufficient liquidity, competition and project attrition.

A hybrid approach which combines Options 2a, 2b and 3 should also be considered, as this could fit the potential mixed directiveness of the approved SSEP and align with some asset classes where developments will have limited locational flexibility. Under this approach, CCTs could be applied more flexibly.

We also underline the need for transitional arrangements as this will be critical to maintaining investor confidence. Lastly, the Government should avoid any changes that would destabilise investment support mechanisms.

Alongside our answers to the consultation questions on Siting and Investment Levers, our response includes views on the Reformed National Pricing Delivery Plan as a whole, including governance arrangements, constraint management, balancing reform and flexibility.