Transmission /

Locational pricing and decentralized energy with Sarah Honan (Head of Policy @ The ADE)

Locational pricing and decentralized energy with Sarah Honan (Head of Policy @ The ADE)

25 Sep 2024

Notes:

Could zonal pricing be the solution to reducing energy costs while enhancing grid resilience through a decentralized system? Although the second REMA consultation dismissed nodal pricing in the wholesale market, zonal pricing is still being considered as an option for the UK. As the electricity system transitions toward a more decentralized model, what changes are necessary to support the integration of millions of new assets, and how can the system evolve to ensure this transition is successful?

In today’s episode, Sarah Honan, Head of Policy at the ADE joins Ed porter. Over the course of the conversation, they discuss:

  • The debate on zonal vs. national pricing under a new Labour government.
  • Key features of successful demand flexibility implementation.
  • The ADE's position on locational pricing, highlighting its potential to reduce congestion payments and benefit consumers.
  • Potential impacts of locational pricing on existing investments.
  • The ADE’s recent report, Demanding More, the importance of NESO to implement a strategic and inclusive approach, considering the needs of both current and future consumers.

Mentioned in the episode

Demanding More - How the National Energy System Operator Can Empower Energy Demand.

Decentralised Energy Conference - 30th October 2024, The British Library, London

About our guest

The Association for Decentralised Energy (ADE) is the leading trade association for decentralised energy, representing more than 150 interested parties from across the industrial, commercial and public sectors. With the goal of advancing the widespread adoption and integration of decentralized energy solutions for a sustainable and resilient energy future, ADE is on a mission is to champion the transition from traditional centralized energy systems to a decentralized model. For more information, check out their website.

About Modo Energy

Modo Energy provides forecasts, benchmarking, data, and insights for new energy assets - all in one place.

Built for analysts, Modo helps the owners, operators, builders, and financiers of battery energy storage solutions understand the market - and make the most out of their assets.

All of our podcasts are available to watch or listen to on the Modo Energy site. To keep up with all of our latest updates, research, analysis, videos, podcasts, data visualizations, live events, and more, follow us on Linkedin or Twitter. Check out The Energy Academy, our video series of bite-sized chunks explaining how different battery energy storage systems work. For more information on the capacity market and government policy and regulations, check out our written research.

Transcript:

We spent about eight hundred million telling subsidized wind plants to turn off in order to turn off gas elsewhere in the country. This right now, already today, is a scandal, and it's increasingly becoming a crisis. I think about it as this kind of tapestry of sorts. Every new rule change or code modification or service requirement is another thread on the loom into this design that was originally built around these big dispatchable generators. The more we try to weave new threads into that tapestry, the more warped it becomes, and it starts straining into a system that never envisioned incorporating demand as an active participant within the system. The basic premise of the report is that if you are a public body who is the one or one of the only gatekeepers to the marketplace, then it is incumbent upon you when denying access to prove why, not on those seeking access to prove why not?

Hello, and welcome back to Transmission.

As decentralized energy assets form an increasingly significant proportion of demand in the UK, the potential for them to support the grid grows as well. But how can we maximize their contribution effectively?

And what changes are necessary to enable a system where decentralized demand forms a substantial part of the energy landscape?

This week, Sarah Honan, head of policy at the Association of Decentralized Energy, joins Ed to discuss zonal pricing and the ADU's recent report demanding more on how the new national energy system operator can empower energy demand. If you're enjoying the podcast, please hit subscribe so you never miss an episode and leave us a rating wherever you listen. Let's jump in.

Hello, and welcome to another episode of Transmission Today. I'm joined by Sarah. Sarah, welcome.

Hi. Happy to be here.

And today, we're gonna be running through a little bit on zonal versus national, but also a report that's just come out from the ADE about ESO slash NESO, and we're gonna get into what all that means in a second. But before we do that, Sarah, who are the ADE? Who are you? It'd be great to get that context.

Yes. So the Association for Decentralized Energy or the ADE are a trade association representing over a hundred and fifty organizations across the sector.

But we're a really broad church. So we have local authorities, universities, big ESCOs, most of the heat network sector, the flexibility sector. And so because we're such a broad church recently, we decided to really hone our messaging and our asks for the new government through two missions. Those being decarbonizing British heat, which focuses on the infrastructure needed to have wide scale rollout of district heating within Great Britain.

And then also impairing energy demand, which is probably more of an umbrella mission, but it kind of does what it says on the tin. The basic tenet is that the energy demand side should be benefiting as much from the energy revolution as big generators. And that's not something that we've seen at the forefront of policy to date, but something we think needs to be in at the heart of this going forward, especially if we're going to maintain public support for net zero.

Okay. So really simply, distributed heating and making sure demand is benefiting from the energy transition as much as generation is. And can I ask you on an ESCO? You just dropped an ESCO in. What what what's an ESCO?

So energy service company?

Yep. Yeah. I think so.

Yeah. So the big ESCOs are really what when we're talking about big heat network developers.

Okay. Perfect. And today, as as mentioned, we're gonna go into a national versus a zonal debate. And and why why should we be talking about this right now?

Well, obviously, there's a context of a new government. We also have the context that the second review of electricity market arrangements consultation closed a few months ago, so government has kind of and civil service has gone back in to their reading through the, I imagine, hundreds of responses that they got.

But the problem statement for Rima is becoming more acute. And if we think that the previous far more conservative government said explicitly that the market arrangements we have today are not fit for purpose, Why aren't they?

They're not because if you look at the traffic jams on the wires of our great electricity system and the pylons going across the country carrying electricity at high voltage levels on the transmission lines. They are getting more and more congested, and that's from about a hundred and seventy million in twenty ten to one point four billion in twenty two, twenty three, and it could reach three billion before the end of the decade.

That's a twenty fold increase in twenty years, which is madness. And it's also about a hundred pounds for every single household.

Yeah. I was gonna say turning it to a household number is probably where the rubber starts to hit the road for consumers. Right?

Yes. Exactly.

And re some analysis done by LCP Delta showed this, which is kind of the more mind boggling part, that we spent about eight hundred million telling subsidized wind plants, not all subsidized, but mostly subsidized wind plants, to turn off in order to turn off gas elsewhere in the country in twenty twenty one. And that's the equivalent of about enough generation to pair up eight hundred thousand how homes.

So this right now, already today, is a scandal, and it's increasingly becoming a crisis.

Mhmm. And a lot of that stems from the market structures which we've built.

So if you think about when the current electricity markets were designed and established at around the turn of the century, They were built around the idea of a few a few centralized generation assets dotted around the country that were dispatchable. So turn up, turn down, to meet demand, whatever.

And I often think of when we're saying, well, why do we need something big? Why can't we do incremental change?

After the time I've spent in the energy industry, I think about it as this kind of tapestry of sorts, and every new rule change or code modification or service requirement is like another thread on the loom into this design that was originally built around these big dispatchable generators.

But the more we try to weave new threads into that tapestry, the more warped it becomes and it starts bending out of shape and it's straining under trying to incentivize, especially the demand side from our perspective, into a system that never envisioned incorporating demand as an active participant within the system.

So you're saying if you start from a system that is designed for large transmission connected plant, then you try and make incremental change to that to bring in demand side response, you're going to find a system that doesn't work as effectively as it should do. And so that is, broadly speaking, the case for, a more holistic change where, essentially, you kind of take everything you've done so far, chuck that out, start again, and off you go.

I wouldn't put it that far. It sounds quite scary.

Yeah. But that one's scary.

There's there's so much of the foundation the foundations that we can keep, but it's the core principles of what the market is supposed to work around that need to change. Okay. And the core principles are based on on on assets behaving like big generation, looking and behaving like big dispatchable generation in as far as possible. That is not the future we're moving to. The future we're moving to is where the demand is the backbone of the system and system security as opposed to transmission connected generation.

And we start we're starting to see some signs of demand coming through in that more old fashioned or or structured in the old sort of old style way. So the demand flexibility service from last year was was a a a reasonable success in terms of demand showing it's able to be flexible.

How did you think that sort of the the DFS went?

I think the DFS has been brilliant over the last two years. I think it's really it's obviously brought flexibility into the mainstream. You know, it's, I think the first time and possibly the best time of my career was seeing them discuss flexibility on Gogglebox.

Okay.

So, yeah, I think it was a great kind of proof of concept, but, obviously, the sector wants to mature from that, and we need to mature from that. The demand flexibility service was largely manual turned down in domestic situations.

That's not the future of flexibility. The future of flexibility is automated.

Manual turned down. You mean people at homes turn the lights off?

Exactly. Yes.

And and in some ways, do you think DFS was a was a bit of a kind of not not an own goal, but do you think it kind of painted the wrong picture of demand flexibility in that I don't think anyone really wants people to turn their lights off? No. Actually, that really paints a bad image of what demand flexibility is. So would you like to give a kind of a couple of other examples of what demand flexibility might look like?

Yeah. Demand flexibility looks like you plug in your EV charger. You have an optimizer at the back end of that arbitraging it either against the wholesale market or in explicit what we call explicit or contracted flexibility markets. You wake up, your EV is charged, you're an on the wiser. Or similarly, if you have a domestic battery and solar PV, the same kind of concept or a heat pump and thermal storage. Or if your home is energy efficient enough, the thermal store might be less needed.

Okay. So we're more talking here about types of flexibility you don't even notice. So no no reason no nobody's gonna sit in the dark to make the most of their flexibility in their home.

No. I think we've we've done a bad job.

Right. That's the Yeah. I I think I think that was a bit of a mistake actually in terms of how some of the the publicity about DFS came out. It did mean there were some quite funny posts about, like birth rates going up as a result of people turning off the lights. That was a that was an interesting Twitter feed. I'm sure we'll find it.

Oh, wow.

Oh, sorry. X, to keep up with the times. Anyway, we're we're going down a demand flexibility rabbit hole, but I think that is that's that will be useful for listeners to get a bit context of actually what does this look like and what the what does it what has it looked like in in recent years? So maybe to accelerate to the the tapestry idea.

So this concept of, okay, we've been weaving in elements of things like DFS, but perhaps we need a more kind of robust change. One of the big things that now sits on desks in Whitehall is an element of Rima, which is this kind of concept of wholesale pricing. So a choice between a national price, which is what we have today, and a zonal price, which is what we might have in the future depending on kind of where policy goes. What's your what's your take on on on that debate?

So the AD in the politician's answer, the AD has been on an evolution with, locational pricing. So zone of pricing, locational, I'll probably throw the between the two. We've strained for two years since the Rhema con the first Rhema consultation came out to find credible alternatives to location and wholesale pricing. And we have failed again and again.

Saying that, I would be lying, and my members would kill me if I said that all my members agreed with location pricing. It's still a very hot topic amongst our membership.

But when the second RHEMA consultation came along, we decided to take a very laser focused approach to what is best for a demand led electricity system made up of millions of distributed assets working together to support the grid.

And looking at all the evidence that we had to hand. Locational pricing was the best. And you can come at it from two angles. Right? You can say you can come at it from a principled approach and a pragmatic approach. The principled approach, which is obviously more important, is about who the system works for and who the system works with.

And to date, it has been all about, like I said, how do we get enough generation, quadruple wind, as the new government wants to do, without thinking about how we use that most efficiently.

So we're in a system we're in a situation now where we built almost fifty gigawatts of wind and solar, which is more than our fossil fuel fleet at the moment.

But we are not using it properly because we simply can't, you know, do a Marie Kondo and declutter our wires. We need to be able to both transport this glorious generation we're making, but also put rewards back into the pockets of customers who are paying for it. Because there's on the customer side of things, and it's important to say that Ofgem themselves, who are would have been the most, you know, possibly reticent to a locational price, have said that all or most customers will be better off in a locational pricing world.

And so when we looked at all those factors, we said, where is this signal best placed? Who does this risk best lay with? Locational pricing risk best lays with those who are best able to mitigate it, and that's dedicated assets and generators.

And then the demand side can come in and be smart in the same way and also play their role in in protecting the system. On the pragmatic side of things, we've had two years of this. And it's this it's this thing in law called the battle of the experts. So you, as the prosecutor, find a psychiatrist to say my client is crazy, and I'm the defense lawyer. And I say, no. No. They're not crazy.

And so much has gone into consultancies over the past two years. And even those prosecuting the case for locational pricing have not been able to wipe out the benefits case. The benefits case from the government's modeling is about twenty four billion between twenty eight thirty and twenty fifty for consumers, largely by slashing that three billion a year in congestion payments.

That's really difficult to ignore, and it's really difficult to look people and homes and businesses in the face and say, we don't want to do this because it's too hard.

We don't want to give you these benefits and make the system the most cost effective it can be in reaching net zero because it might annoy and perturb a few large generation companies. That's not a very sellable message in this day and age.

Okay. I think there's a load to unpack in there. Let's let's let's let's just let's just do that maybe bit by bit. So so first thing I'll say is that you obviously have a a background in the legal profession.

So you that that's coming through. And then and then let's go into just that that kind of case case for change. So you're talking about a bringing in a a more locational price, which should encourage people to put generation and demand in better locations on the grid, which should mean fewer fewer constraints, so fewer times that the wind or solar is turned down, but also perhaps less spend on wires, which GB. And so that whole system, the argument is run slightly more efficiently and as a result generates, lower cost that you can then pass through to consumers.

So that's that's that's the that's the statement. Yeah. And then onto, perturbing companies. I think this is where it gets quite interesting.

Right? So the one of the big things that we see is this concept of a clean power a clean power energy sector or electricity sector by twenty thirty. And one of the often kind of arguments around this move to a more locational price is, well, actually, we've got quite good progress at the moment. AR six has just come through, and that was a reasonable success, and people are putting money into wind farms.

We are starting to get the build out that the government are asking for, so the doubling of onshore, tripling of solar, and quadrupling of offshore. Like, that is now starting to to happen. And the analogy would be, well, if that is like a f one car racing for the line, then should we take it into the pits and kind of, like, rebuild the engine when actually the thing we need to get on with is getting everything done by twenty thirty?

Nice carbon intensive metaphor.

Yes. Yeah. Other esports are available.

So it's a very good point. And I think there's two parts to this question. One is how long will it take to do zonal to implement zonal? Government said about five years.

Most people, I think, think that's very underambitious.

I don't think there's any reason it couldn't be done in a couple of years with the right political will.

The other point here is that this government has been a government of signals before they even got into power.

Before the actual GB Energy bill was a glint in the shadow cabinet's eyes, They were saying to industry, when we get into power, we are going to move fast, and you better keep up with us. Brilliant. That's great.

They cannot then come into power and say, but we're gonna, like, take steady progression.

That we're going to be evolutionary about this. You often hear about evolutionary approaches and, kind of I have to think, does anyone know how long evolution took? Sure. It's not gonna get us to twenty thirty. The biggest threat to twenty thirty is incrementalism, not visionary thinking.

Okay.

So sending a strong signal to the industry, to the market, get yourself in line, a big change is coming because this the system was never built to do this. Or these markets were never built to do this. So why should we expect that they are able to deliver what we need to be delivered?

And if that signal is sent, then I think industry will step up.

And so the kind of the most fundamental part of that, right, is this kind of this high cost by twenty thirty Mhmm. Potentially going to high cost by twenty forty, etcetera, where you're saying, effectively, when you move to a net zero system that has solar and wind and you don't have necessarily the transmission capacity that that that can kinda keeps pace with it, you'll end up with a big cost coming from balancing. And that is not something that a any government would would would really want to see because what that will do is it will kind of, hinder and and stop progress in terms of in terms of build out. So that is kind of you're saying that is the critical thing that is perhaps more important than whether or not something happens by twenty thirty, or you're saying, actually, we shouldn't even be worried about the the kind of problem statement of this is gonna take too long to do because if the government gives the right signals, we'll just get it done.

I I think it's twofold. I think the main point that I'm I'm trying to make is that if you give a signal to industry now that steady is the course, which is what would be done if you didn't choose zonal, then twenty thirty won't happen anyway because there won't be a strong enough impetus that we need to get moving and we need to get moving fast.

Because at some point, those costs will bite and that will slow down the rollout.

Is that Well, it's just the the amount of acceleration that needs to be put into the change.

So you're basically saying, okay. Yeah. Everything is kind of okay. We just need to tinker around the edges.

We all know what tinkering around the edges does. It doesn't get us anywhere fast. It will get us there, but it won't get us there by twenty thirty. Whereas if you say, right, we're ripping up the rule book.

We are going out. We're going strong, then that will get everyone moving faster.

Okay. Okay. No. I I I I like it. And I think when we saw things like electricity market reform from in the early teens, once people could see what the thing was, they could get behind it.

Yeah. Actually, there's no sort of aversion to zonal zonal markets by investors. Investors put lots of money into zonal markets all the time. So Yes.

Well, I've got a nodal market, but zonal markets, Norway, Sweden, other parts of the US. Right? They do attract a lot of investment. So Yeah.

Okay. Interesting. Going back to that point around perturbed companies. So one of the things that kinda comes back quite often is, well, yes, you can make that change, but that's gonna affect me in my business.

And to be fair to lots of these companies, they've been developing that site for, say, ten years. Mhmm. And they're now in the stage where they're starting to to to really ramp up investment. And it gets to the point where all of a sudden they want to build that thing.

But if it moves to a zonal system, the reward for building that site will change. How does this kind of how would it move from a national to a zonal system? How would it deal with that? How would it make sure that investors are able to maintain confidence in the GB electricity system?

So there's there's the future investors, and then there's the investors that have already invested. Yes. And there's no question that strong legacy arrangements and grandfathering will be needed, including change of law clauses, all of that within contracts. And government has or at least the previous government and civil service, have done a massive amount of work into that already.

Can I pause? Grandfathering. What does what does grandfathering mean?

So grandfathering is taking something taking an arrangement that you have now and then saying you made this investment in good faith, and you signed lots of contracts on good faith, and you put lots of money in in good faith.

We will honor those arrangements for a certain amount of time as these changes were made because you made this decision with certain assumptions in mind.

And so it's a way of it's an off ramp almost. It's a soft landing into these new arrangements.

So you're saying you were expecting to make a hundred pounds in the old arrangements. Yes. We've now changed the arrangement. It's gonna be you're gonna get eighty pounds, but, actually, we're gonna top that up to make sure that Yeah. You as an investor in this space aren't getting really negatively impacted by the big changes. Okay.

Yeah.

So then onto onto some of the other other parts that we've often heard talked about in terms of zonal versus national. So one of the things that comes up quite a lot is even if you move to a zonal system, you get high power price in London. But, ah, gotcha. You can't build wind farms in London. So what happens next?

Well, no one's expecting to build wind farms in London, and that's why we come back to the demand side as in the, obviously, the modeling the big, big piece of modeling FTI did for both Ofgem and ESO found that it now in a nodal system, so it has to be caveated a bit, that demand flexibility becomes the biggest form of flexibility in a nodal system. So about fifty nine gigawatts, so you'd have to temper that for zonal.

Sorry. Just to just to say, that's fifty nine gigawatts of flexibility from the demand side in GB?

Yes. Yeah. In a nodal system. And I think batteries was in the twenties. But if you compare that to fifty gigawatts of offshore wind, that's insane. And it's such an amazing future to think about that those price signals would be there to make sure that the demand side, as I said, is being rewarded just as much as the generation it's subsidizing.

So that's one thing. So you wouldn't be building wind farms. You'd be flexing demand. Mhmm. The other side of it is what you referred to earlier as the kind of investment signals for zonal pricing as opposed to the operational signals. So demand flexibility is operating in the most efficient way. Investment signals go to where should you place your data center, where should you place your electrolyzer.

And and how does that work today? How do we get investment signals?

Well, the investment locational investment signals are supposed to be sent through the transmission network use of system charges to new us, but they've never been they've clearly never been very effective because we're having this conversation.

And it they're also so some people say, just reform to new us. Just reform forward charges in to new us to send a stronger locational signal. One, most of the generation site doesn't really want that. And two, the Chnoo House is not something you can hedge against. It's basically a tax. It's not something that you can properly predict. And so this idea of investor uncertainty from locational pricing can just as easily be made for Januwels reform.

K. So so imagine this future world, you've kind of got two options. You could either go down a national let let's say we're just talking about the investment signals, location investment signals. You can either go down this world of having a national price with some sort of uncertain tenuous reform to give you something that looks slightly different, but it's hard to predict, or you can go down the road of having locational prices that is something that you can track and we have seen in other markets that people are able to hedge those risks. Okay?

Exactly.

Okay. That balance. Okay. Great. Alrighty. So I think we've we've kind of covered a lot of the the the zoneal and nodal piece.

Right now, it's kind of on the desks of people in Whitehall. So, hopefully, we've done that, a good wrap up of kind of where that debate is and kind of what the key points are within it. Before we move on to ESO to NESO, which we'll talk about in a second, any final thoughts or comments around the zonal and national pricing?

I think the point is that we have to remember that we need to bring people with us. And I think the story we haven't told so well within the zonal nodal or zonal nodal national debate is because we've had all the evidence on our side. And I'm saying this as a noob to the zonal club because we only came out in favor in the second consultation.

But because we've had all the numbers and all the modeling and all the quantitative evidence, we've kinda just gone, well, it it's very easy.

Just do it.

Just do it. But what we fail to do is tell the story about what the system should feel like for customers. The system should not feel like missus Megan's, in one part of her bill, pays to subsidize. And, yes, they need subsidies, and we absolutely need that, forgetting to net zero. I don't want any misnomers around that. On one part of her bill, paying to subsidize wind farms.

On another part of her bill, paying to turn off those wind farms Mhmm.

And then what's left for her.

That's not a net zero future that we will be able to achieve. Mhmm. And it's not a society or a system we should be aiming for.

Okay.

Let's leave the world of Zonal National, and then let's go into a more recent publication from the ADE. You have just published the ESO to NESO piece, which you're calling Demanding More. So what what was the what was the intention of that piece? What does it try and cover?

The intention of the piece is quite simple, I think. The previous government, through the Energy Act of twenty twenty three, set the groundwork for the establishment of a new public body, the National Energy System Operator, that would evolve from the electricity system operator and would have wide ranging powers across the whole energy system. So its legal duties can be split down very simply into a duty to provide strategic advice to government, a duty to and the regulator, a duty to operate the transmission electricity system, and a duty to strategic plan.

And we've worked collaboratively and productively with the electricity system operator, the ESO, for years and have done some really good work with them and have seen them progress and do some really good work. But in the two years that the NESO was announced, since the NESO was announced, We haven't seen the rate of change that we think is necessary and incumbent upon a public body.

So this idea of a new national body that has power over critical national infrastructure.

Kind of coming back to this evolution versus transformation approach, we think it requires a reformation, not an evolution.

And we are ready to work with NISO to do that, but, actually, we think a lot of this has come really from perhaps government and Ofgem underestimating the extent of regulatory changes that the industry was expecting with the formation of NISO.

And turning that into, like, a concrete example of one thing you think might be might be missed as part of that transition. Like, where where where can you see that kind of from your experience of interactions with ESO as well as with government? Where where can you see that kind of going wrong today?

I think the biggest thing, and this is the biggest thing that comes out in the report is I'm sorry to go back to the the law terms, is the burden of proof.

K.

So if you get into a conversation with ESO about, you know, a service requirement or a market rule or anything, the conversation will generally go, well, why is this a problem?

This is a technical requirement. We can't do anything. If we were to change it, how many megawatts could you bring me? Which I always think is kind of the telling question because it basically tells you that it's not a hard and fast rule. If you can give them enough megawatts, then you wouldn't they they would change it. So it's clearly not, you know, dye in the wool engineering.

And it is our basic premise, and this is the basic premise of the report, is that if you are a public body who is the one or one of the only gatekeepers to the marketplace, then it is incumbent upon you when denying access to prove why, not on those seeking access to prove why not.

Mhmm.

And that is not a change we have seen over the years.

Okay. And if I if I was to put myself kind of within the shoes of of ESO and ESO and say, well because denying access is I think it's a I think it's a really interesting way of describing it. So if I if I can't put myself in in their shoes and say, well, I'm trying to run the system. I'm looking for the things that will have kind of the biggest impact that I can see and I can I can call on, And I have resource to spend, and I want to spend that resource to get those things into the system?

And that's kind of that's that's kinda how I see the world, and I'll and I'll kind of prioritize for something that looks like that. I feel like that's probably how they think about it. But you're saying as a part of a change from ESO to NESO, that approach is probably not the one they can take. And, actually, they can't be running that prioritization.

And, actually, they need to make sure that everything is given kind of fair shot at at the market.

Is that is that the It's very fair, but it's also one of those total law nerd moment. Fascinating things about when you really dive into the legislation Okay.

Because their licenses as a private body was all about system operability. Running system, lowest cost, keeping the lights on, Bob's your uncle.

Mhmm.

In the law, they have a duty to have regard both to the to the needs of current consumers and the needs of future consumers, and both to have regard to the needs of the current whole system and the future whole system. So no longer can we say if it keeps the lights on today, grant. Job done. We have to be strategizing for the future. So there's this idea that there are gigawatts of extra man. We talked about EVs. We talked about heat, industrial electrification.

There are gigawatts of extra demand coming onto the system that at the moment, control room has no visibility over.

The question is, do they want access to that and visibility over that and to be able to use that, or do they want to pay high cost gas to meet its needs?

And I should clarify, Control Room has a good feed of aggregated demand, but you're explicitly referring to kind of individual assets at the distributed level.

Yes.

The yeah. Okay. Good.

And so if if ESO goes to NISO or when ESO goes to NISO and they want to be considering the kind of future consumer as well as the kind of balancing work they do at the moment, like, what do those first steps look like?

What are what are the recommendations that you're kind of saying, this, you Well, this is what's really important is that most of our recommendations are actually for government and Ofgem.

Okay. And most of our recommendations within that are for Ofgem. So we think regulatory changes needed to be need to be made to the licenses in order to build that burden of proof into their license obligations in order to build better ethical walls in the business, because, obviously, this is this massively expanding business now with duties across whole systems. And when you're benefiting from a function, you shouldn't also necessarily be the one designing that function. So if ESO is benefiting from a market design, then they shouldn't necessarily be the one always designing it. So this kinda comes to the market facilitator question.

And then also that it's explicitly made clear that the discrimination, the on the face of a discrimination of assets in the design of ESO services is prohibited within the licenses. But we also think ESO has a long way to go through good regulatory design by Ofgem in that kind of cultural transformation of changing from a private organization to a public body. What we say a good bit in the report, and, again, this is an Ofgem question, is transparency is not synonymous with accountability, and that seems to be lost at a lot of times. ESO, I think, have made really, really good strides toward better transparency.

But if you just tell us that there's, like, red flags next to access for all your markets for the the demand side, but then don't say what you're gonna do to make that right, it's kind of just a bit sad. Yeah.

So linking that, okay, we've got the transparency. Now how do we translate that into accountability?

Yeah. And I'm sure that, you know, we'd look at other markets like this this this same dilemma or challenge of kind of how do you start to bring these assets into, transmission system operator and across a whole national energy system. How do you actually start to manage that best? That same thing has been grappled with all over the place.

Mhmm. And so if we can start to do that in a a really efficient way and lower cost to consumers, then then I'm sure we'll see movement from Nissan to to be supporting that. Very interesting. So I think the the the final two things that I wanted to to run through today.

So one, is there anything that you would like to plug?

Well, apart from reading Demanding More And we'll add that into the show notes of the of of the episode.

And then also, we do have our decentralized energy conference coming up at the end of October. So that will be in the British Library for the first time. So we'll be having all these conversations and more. But also just to get involved with the ADE and our missions, because now that we have these two missions driving the work that we do, we're finding it's a lot easier for people to understand, what we're doing and what we're aiming for.

Okay. And last question. Is there what is your contrarian view to something that you believe that the rest of the market does not?

I won't say the rest of the market, but what I will say is going from I I was flexibility policy lead before head of policy at the AD, so now I oversee heat and heat networks as well.

And heat being at the heart of all this is something that's really overlooked all the time.

And if you actually think about it in a very perverse way, if you exclude it, heat from clean power by twenty thirty, that would make Chris Stark's job a lot easier because that's gigawatts you don't have to worry about. But that would be the wrong way to go about things, obviously.

It should be more holistic and understanding the role that different kinds of decarbonized heat, different kinds of solutions, whether it be district heat, shared ground loops, individual air source heat pumps, communal heat networks, whatever, That they are also going to be a backbone for the flexibility of the system and for system security.

In a world where it's not the darkest night of the year, that is the kind of scary time for electricity control room, but is a more constantly, constantly changing system and constantly moving dial that's much more volatile than we are today.

Heat needs to be brought into that in a far more concentrated way than it is today.

And is that maybe to say heat you're almost seeing is like an opportunity in terms of the the flexibility that heat brings rather than Absolutely. Most people in industry see this heat as an enormous challenge and how on earth do you sort of build the electricity system to manage it? But you're saying, actually, within within heat, there is flexibility. Mhmm. With that flexibility, we have opportunity.

Exactly.

Okay. Lovely place to leave it. Yeah. Sarah, thank you very much for coming on.

Thank you.

Much appreciated. And, as mentioned, we'll drop in the show the show notes the the key documents to talk about today.

Brilliant. Thank you so much.

Thank you for listening to Transmission, a MODO Energy podcast. Transmission delivers conversations from industry leaders and experts exploring energy markets and the operations and technologies related to grid scale battery energy storage. Check out our other episodes by searching transmission wherever you get your podcasts.

Check out the Energy Academy, our video crash course on how markets in Great Britain and ERCOT work, or head to motoenergy dot com to see our written research Thanks for listening

Modo Energy (Benchmarking) Ltd. is registered in England and Wales and is authorised and regulated by the Financial Conduct Authority (Firm number 1042606) under Article 34 of the Regulation (EU) 2016/1011/EU) – Benchmarks Regulation (UK BMR).

Copyright© 2026 Modo Energy. All rights reserved