Grid connections and connections reform with Catherine Cleary and Joe Colebrook

Comes down to risk and who takes the risk. Historically, networks don't like to take risk, whereas developers, obviously, and people trying to build these assets want them to take more risk and don't wanna have the risk themselves. So it's really hard to balance that and I guess that's where the regulator has to come in and kind of get us to agree on who takes what risk. Distribution is almost playing catch up with transmission in the sense that, transmission you have a balancing mechanism. Distribution is only starting to have distribution system operators, DSOs, and also a flexibility market itself. Until you have that flexibility market, it's very difficult to for the network to take that risk because there's not a lot they can do when things go wrong, right?

The kind of impact that this has, the reason we're all talking about this is because obviously connections reform is sort of needed because of the level of upgrade work that's been triggered. There is a very clear proposal in connections reform to have more ambitious less pessimistic assumptions regarding battery operation which should help reduce some of those kind of connection time frame delays.

Grid connections are one of the most pressing subjects for anyone looking to connect a renewable project or battery storage system to the grid.

And connections reform will set the precedent for all projects in the connections pipeline.

Today, Catherine Cleary, specialist connections officer at RoadKnight Taylor, and Joe Colebrook, head of grid connections at Inova, join Ed Porter to discuss all things grid connections and connections reform. If you're enjoying the podcast, please hit subscribe so you never miss an episode and give us a rating wherever you listen. Let's jump in.

Hello, and welcome to another episode of Transmission. Today, we have two guests for you, Joe and Catherine. Welcome to Transmission.

Thanks, Richard.

Thanks for having us.

And to get started, Catherine, can I come to you? What is your role? What do you do within the the energy space?

Yeah. Thanks. So I work for a company called RoadKnight Taylor who are a very small, grid connection consultancy. So I'm one of their connectologists, which is, basically what it says on the tin. We we advise and help, get all types of customers connected to the grid. So that might be demand, generation, kind of really large scale transmission project. It's a much, much smaller sort of, you know, anything down to a kind of community energy scheme connecting to their local distribution network operator.

Superb. Joe?

Yep. Hi. Thanks, Harvey. So, I am a head of grid connections at Inova.

So, I manage a team that, basically, deal with all the networks, in in the UK.

Inova are a renewable energy business. So our long term mission is to, build, energy hubs with multi technologies to, try and, help end users reduce their impact on the grid.

Superb. And so, hopefully, we've got a bit of a mix from sort of the commercial and the technical side today. And to kick things off, I think we're gonna do a bit of a connections one zero one. So, Joe, starting with you, from the commercial side, what does the process look like in terms of going from idea around energy project through to connected project going live?

Yeah. Okay. Yeah. So, yeah, one of the key parts of grid connections is all about managing your agreement and your contract with the electricity network. So, when you first have a project, so you'll find some land, you'll talk to a landowner, you will apply for a grid connection and that sort of sets off the process of how you're going to connect to the grid, how much it's going to cost.

Once you've got that, you'll then sign that offer and you'll basically keep collaborating with the energy networks to, as you develop your project, they will develop their part of the connections. They often need to do some work to connect you to the grid, and you'll basically work through with them over your lifetime of your project. And then you'll get to sort of the end where you start operationally and you start being in operation.

And at that point, you, you know, you'll have an agreement of, of how, how you work with, the energy network Okay.

And, you know, what you can and can't do.

Okay. And best case, kind of worst case, what what does, like, in terms of time frame for that process?

So it depends. Like, distribution and transmission are very different. So distribution, you know, you could be looking at, assuming you've, you've applied for a connection before planning, which is the general way you do it. You know, you could be looking at sort of three or four years, maybe two at best case, you know, Whereas at transmission, you know, you've you need sort of even once you've got, planning, you'd need sort of three years to to do all the procurement and to to do the works because everything's a lot bigger. Things take a lot longer.

Okay. And we just talked about distribution and transmission there.

So maybe just to remind people the difference between those two networks.

Yeah. So distribution is your, I kinda like to explain it as, your distribution is sort of your your local, level network. So it's a bit like your, B roads and your green roads, maybe even your A roads, if you're, you know, if you're using the road analogy.

Whereas transmission, as the name suggests, is there to transfer bulk power across the country, so it's more like your highways. It's, you know, it's there's less of it, but it's much higher power that is going through it.

Okay. And, Catherine, so from the engineering side, so, obviously, Joe has kind of made his application, and there's the commercial process going on. There's the kind of contract management going on. But from the engineering and technical side, what's going on from what's going on in the network operator's mind?

Yeah. So so I guess, you know, if I'm sort of sitting on the engineering side, once you get that application from a customer that says I'd like to connect, there needs to be some kind of evaluation of the impact that customer's gonna have on the network. So, you know, if you were to take the example of a sort of maybe a fifty megawatt, battery site, your network engineer would now look at saying, okay. Well, what's actually what actually happens when that battery wants to charge from the network? So when they're drawing power down, what are the kind of power flows that go through the assets in the network? And that might identify pinch points. So, you know, particular, pieces of equipment that could be sort of overhead lines, or substation, equipment that needs to be upgraded.

And and that's a kind of, you know, effectively a kind of a power flow analysis that might look kind of, I guess, in in quite a lot of depth at the different loadings on the network at different times of year, things like that. So it's quite a lot that goes into that kind of consideration. So that's the first thing. And, obviously, they need to consider things like when the battery was exporting as well, so all the kind of operating conditions.

But the second point is that physically, you know, Joe's fifty megawatt battery needs a a point of connection. So, actually, apart from the load flow kind of engineering piece behind the scenes, we need to look at what are the physical assets that I just need to be able to build out to extend the network to connect Joe. And and in the past, perhaps that's been quite a simple exercise. And as we're seeing more and more applications come in, more and more competition for customers connecting at maybe the same substations, actually, that physical infrastructure just extending the network out is becoming quite challenging.

And which of those two is kind of the bigger problem?

Right? So is it the kind of the the almost like the heat map modeling of what the network looks like and where are the pinch points? Or is it the kind of, oh, we need to just bolt on an extra transformer and an extra sort of yeah.

Is it Yes.

So so it always used you know, I think I'll I'll simplify. It always used to be that it was the wider kind of power system flows that would do things like delay your connection. So I'd, you know, I'd work out actually there was a a an overhead line that was overloaded. We needed to build a brand new transmission circuit. Sorry, Joe. You're now gonna have to wait for twenty thirty seven for your connection date. So that was the kind of the things that spell really bad news for a project.

Whereas, you know, okay. Worst case, if I have to maybe to extend my my network out to you, maybe I have to go and extend a substation, perhaps, like, lease some extra land. You know, that that that was sort of the worst case scenario on the physical side. I think now we're in a situation where the physical side is beginning to catch up as being an issue as well because we are seeing so many connection applications that you're getting to the point where, you know, I think some of the largest transmission substations that are being planned, you know, just in order to physically connect everyone, you're needing enough bays. You know, bay is what we connect each project into. You're getting substations, which sort of, you know, football pitch sized substations. You imagine kind of going through the planning process to say we'd we'd like to build a football pitch sized, you know, metal substation, which is gonna be loud and noisy in your backyard, and that becomes a bit of a deal breaker.

So so that that physical infrastructure piece, I think, is becoming really And, I mean, there's now some where they're even having to build two new substations because the first one isn't big enough.

So, yeah, it's it's and that's at the four hundred kV level with the transmission level, which is quite phenomenal when you think about it.

So how is battery operation being considered in that process?

So I think it's a really important point because, historically, network operators have taken a very risk averse approach to batteries. So they've said, we don't know absolutely how you're going to operate, so we'll assume the worst case scenarios. So we'll assume that you're, you know, you're exporting when other other generators are exporting, you're importing when other customers are exporting, importing, sorry, which obviously triggers kind of more network reinforcement. It shows up more pinch points.

I think the whole industry has agreed that's that's not the right approach. It's overly pessimistic. But actually agreeing what is the right approach is quite difficult. So we could go the whole hog and assume that batteries always do the right thing, and they always help the network.

That might not be possible. You know, your battery might have a limited sort of state of charge or something like that. So so at the moment, we're in a situation where the transmission network operators and, and the transmission system operator, NISO, that's the national energy system operator, have, some con construction planning assumptions is what they're called, quite technical, assumptions, which basically hold batteries in a sort of neutral position. So we assume they don't help because they might not be able to, but we assume they don't make the situation worse.

At distribution network level, that's not true, and DNOs, are still in a relatively sort of, pessimistic scenario, assuming that batteries might make constraints worse. That difference is is gonna we'll probably come to it later. It's it's sort of, you know, triggering a bit of a kind of an issue.

Okay. And and are the are the DNOs allowed to kind of make their own mind up about this, or is it is it kind of baked within a more central, centrally planned process?

So the, there are some codes so the, that all the DNOs, have to abide by certain engineering standards, which the the network, association publish. So there are some basic provisions that talk about sort of the security of supply that network operators have to provide. They do actually have quite a lot of flexibility. So I think if anyone says, oh, no.

We wouldn't be able to consider the the flexibility of a battery asset. You could point them to some sort of, you know, some of the distribution system operator, parameters, which say, no. Actually, you could you could be a bit more flexible. But it does need more modeling.

So To add one more bit.

So I think it's a really good point around batteries could import or export, at nearly any time, particularly if they're doing frequency response. And if you go back to twenty twenty two, batteries by and large nearly all did frequency response. So kind of always either importing or exporting depending on kind of where the frequency was. If we kind of accelerate to twenty twenty four, we've got, like, four and a half gigs of batteries, one and a half gigs more or less does frequency response. So one and a half gigs needs flexibility in both directions and so could hinder the network in some cases, theoretically.

Yeah.

But the the bulk of the assets that are there, the three gigs that's left, they actually aren't providing, frequency response. And so they very much explicitly could be doing the right thing for the network always. And so to me, it feels like there could be a a kind of an agreement that's reached where for some assets, yes, they do frequency response. But for others, it's much more of a, some, yeah, some assets will kind of be always doing frequency response, but other assets could be much more curtailed or have network management orders placed upon them. Joe.

And I that's not a bad idea. I think that the the thing that we gotta think about here is that it comes down to risk and who takes the risk. And the the more aggressive your assumptions, the more risk that the networks have to take. And historically, networks don't like to take risk, and in fact, there's not really an incentive for them to take a risk. Whereas developers obviously and people trying to build these assets want want them to take more risk and don't wanna have the risk themselves. So it's really hard to balance that. And I guess that's where kind of the regulator has to come in and kind of a kind of get us to agree on who takes what risk.

And I think also distribution is quite different because distribution is kind of trying to almost playing catch up with transmission in the sense that, transmission, you have a balancing mechanism.

Distribution is only starting to have distribution system operators, DSOs, and also, a flexibility market itself. So some of these are some of these are more advanced than others.

And until you have that flexibility market, it's very difficult to for the network to take that risk because there's not a lot they can do when things go wrong. Right?

I suppose and but coming back to connections reform and the kind of impact that this has, the reason we're all talking about this is because, obviously, connections reform is sort of needed because of the level of upgrade work that's been triggered. There is a very clear proposal in connections reform to have more ambitious, less pessimistic assumptions regarding battery operation, which should help reduce some of those kind of connection time frame delays.

Okay.

And we've we've kind of seamlessly moved into connections reform, but I think we absolutely should, instead of perhaps talking about what connections reform is, which has kind of absorbed a lot of the airwaves for, this year, I think Talked out on that.

Yeah. Yep.

Yep. I think a lot of the industry are. I think we should maybe look forward. So instead of kind of talking about what that particular, reform looks like, I'd like to kinda get your take on actually what would be the what would be the sort of the ideal solution.

So if you were kind of given kind of free rein to do whatever you would like in terms of where that reform gets to, what would it look like for you?

Joe. Well, I get to go first.

If I could do anything I like, well, that's that's a lot of power. But, no. So I think we're actually, I think, getting into quite a good place, like, fully acknowledge that the previous system didn't work and something needs to change. Right?

And the current proposals by NISO are pretty good. They go quite a long way to fix a lot of the problems.

But I think for me, it's, we still need to acknowledge more about how the developer business model works.

You naturally as projects get more, developed, you spend more money on them, you derisk them, they become more certain. So when a project first starts, it's speculative.

Right. And I'm gonna use the word speculative. I know it's a bit of a controversial term, but whenever you start a project, even just getting a piece of land, that is a speculative project. You have to go through the process to make it not speculative. Every project that was ever built, whether it's a nuclear power plant or something else was speculative once.

And so it just needs an acknowledgement of how that process works and to blend that in with the connections process itself and how we manage the queue.

So for me, it would, I think, queue management milestones are really important because they set expectations and they set the agreement of how you're going to develop your project.

So I would I would absolutely keep those in.

I think that with the with the capacity pots that we're we're we're gonna have introduced, the the danger is at the moment is we're gonna set the limit of what we need, but that the one thing that really doesn't deal with is is the fact that some of those projects will never get built. Like it just by nature, the way the business model of developing works. So we need attrition in some form and Anova, have suggested in our in our consultation, recent consultation, we suggested to actually do something which we do in our business anyway, which is apply a project success weighting. So if you've got a queue and, you know, some of them have got only got land rights, you would apply, let's say, a fifty percent project success waiting. So a ten megawatt project will actually look like a five megawatt project in the queue.

Or if you've got planning, you might it might be more certain, right? So if you've got a whole queue of everything's got FID or you know, everything's had an investment decision made, that's one hundred percent basically they're going to be built. You're like, well, we're not going to let anyone else in. But if you've got a queue full of projects with land rights, you'll go, well, I'm gonna keep keep letting people in because a lot of those won't be built. K.

And maybe two maybe two things in there. So so one, you snuck in connection parts, so we'll we'll come back to that. Sorry. But but but two, in this concept of, like, derating a connection, if you derate it to, say, ten megawatts to five megawatts and it looks like five megawatts in the queue, that might be fine in terms of physical connection that's available. Everything but the billing, as it gets close to delivery, it becomes ten megawatts. That might trigger wider reinforcement. Is that is that what you mean?

So I guess there's maybe something maybe we need to explain how a queue works in in connections. Right? Because we've talked about there's the physical work you need to do at the sub sub substation, the local work. Right? That, obviously you need to plan for the for the ten megawatts so that project is right. You can't plan for a five megawatt project and then build it later as a ten, doesn't work. But the wider works, so a queue is just a queue is there is a queue behind every piece of work.

So when people talk about queue, it's not necessarily a big long queue.

It's what it's, projects that have to wait for a certain piece of reinforcement to be done and some projects have to wait for multiple pieces of reinforcement.

So, that piece of reinforcement is enabling lots of projects. So that is more what I'm talking about where this project success weighting, you will allow more projects.

You would assume more projects are gonna be given a connection date when that's built. So more projects it will enable more projects when that's built acknowledging that obviously some of those will fall away. And then by the time hopefully that piece of work is built, a load of all those projects have developed at the same time and they've all got planning and some haven't, some have, and it kind of works out that you get the right amount of capacity for that piece of piece of reinforcement. The, obviously the risk is that you over, over connect it or you have an oversupply.

And I think as long as that risk is clear and there is clear who's taking that risk, whether it's the network who has to pay more in balancing mechanisms, costs, or it's the, or it's the developer who would get a delayed connection date, as long as that's clear, I think we it can be managed.

K. And maybe, the connection pots, Catherine. I'll come to you to to have a go at the connection pots. But then, what does kind of the ideal outcome of the connection reform look like for you?

Okay.

So connection pots, this was the idea people are probably familiar with perhaps the terminology of, TMO four plus, which was what, what NISO The worst acronym in the world.

Jay's words, not mine.

Sorry. Later.

Regardless what the said for that, that was the kind of, first working through of connections reform and introduced the idea that there'd be some sort of criteria that you had to meet to get into the new queue, and that that criteria was called gate two criteria, and it it was broadly speaking going to be land rights. The world has moved on, right, quite quite a lot, quite rapidly.

And we've introduced the second idea of, connections being aligned to, what the Labour government are calling the clean power twenty thirty plan, which, you know, sets out a specific well, in fact, sorry. The actual plan is gonna be published in a couple of days, so we don't know what it sets out. But but we are expecting to set out, some, kind of overall gigawatt targets for the amount of, you know, wind, solar storage that we need to meet that kind of clean power objective. And the idea is that that will be subdivided into zones around the country.

There'll be zones at transmission, zones at distribution. And within each of those zones, there will be a set of pots. So solar, for example, in, you know, perhaps, South Wales will have a pot. So a megawatt allocation might be, you know, five hundred megawatts distribution.

It might be two thousand megawatts at transmission. So but but a kind of effectively a cap on the amount of that technology that we are anticipating the network will connect between now and twenty thirty.

And the controvert you know, this is quite a good idea. As an engineer, I love it. You know, we can design really well once we've got things like a kind of, you know, set criteria of pots of different technologies. So we could design a really efficient network, so that'd be great.

But the controversy is obviously how you fill the pots, which projects make it in and which projects don't. And the the the proposed at the moment is that projects will make it into the pot or not, based on their planning status. So you put fill the pot first with projects that are consented. If you still got some room in the pot, you put in projects which, have submitted their planning consent but not yet got consent.

And then if you still got some leftover, you, you put in the projects which you've just got that kind of land rights. So that's where, you know, coming back to Joe's point, this idea of if most of your pot is filled with projects, they've just got land rights, maybe your pot should be inflated a bit to take account of that. So that's the kind of pot's idea.

I was also gonna timestamp your your comment about the, clean power plan in that today is the twelfth of December. And so when this comes out, we probably well, we will have a fully fledged, clean power plan. Hopefully. Hopefully.

I like your confidence. Yes. I'm sure we will.

Okay. Sure we will. Okay. And then and then from, the pots to your view of what a ideal outcome on connection reform would look like.

Yeah. So I think, I I echo a lot of Joe's points, definitely the point about kind of attrition. I suppose the the other point for me perhaps is that the, as I said, this kind of idea of pots, it does give us a lot of opportunity to optimize.

I think that for me, connections reform for the first stage of it. So going out to twenty thirty is like a a big sort of eighty twenty exercise, I e, it's a bit rough and ready. Time is sort of of the essence. We could spend years getting this absolutely right, but it would have no point because effectively everyone would have been delayed, would have carried on perpetuating the kind of queue issues we have today.

So we've sort of got to move fast, and I think one of the reflections of that is that it won't be perfect. So actually kind of being quite clear about what we're implementing, and I I I agree that actually there has been a lot of work that's gone into the proposals. They've changed. They've iterated.

They are iterating still. Right? You know? So I think that's something that we should all be quite conscious of.

You know? We've had lots of consultations and things, but actually, NISO's plans have been in the background, you know, changing again and again to to what's it reflect that that those kind of feedback responses.

So I think lots of things are changing. We sort of now need to get to a point where we we fix that methodology.

It won't be perfect.

We probably need to ensure because it's not perfect, there are some undesirable outcomes. One of the biggest undesirable outcomes would be that actually everyone has to pause everything for the next year whilst the the engineers, I'm afraid, go away and restudy the networks and work out exactly what the impact is and and when people can connect. We don't wanna do that. Right?

If you're a project that was due to connect in twenty twenty six, twenty twenty seven, you need to be making investment decisions now or next year. So we want to kind of get that sort of investor, sort of hiatus risk out of out of the way. So I think there need to be some sensible exemptions. There's been a recent, announcement from NISO, a letter, an open letter to Ofgem, which outlines some potential exemptions, which I think is really great.

So Let's let's do those exemptions.

Yeah. So, so the NISO have proposed that, so people probably might be aware that the original proposal was that pretty much everyone would be caught up in connections reform. So you'd need to wait until the end of next year to work out whether or not your connection date was still valid.

The only exemptions of projects already in construction who were gonna be complete by the end of twenty twenty six. Based on feedback, NISA have proposed adding to that that list of exemptions.

Any project which, by by the twentieth of December, so probably by the time this has gone out, had submitted their planning consent and receives that planning consent for their project prior to the implementation of connections reform. So sort of expected kind of May, eight maybe April, May next year. So projects effectively, which are consented by April, May next year, would be in the clear.

They they would they would be able to proceed As long as they've submitted planning by the twentieth of December.

As they've submitted planning by the twentieth of December. Yes. So if you were, you know, really quick turnarounds for for kind of smaller projects wouldn't be allowed. But, so that that's one exemption. Another really important exemption, is that something which has a government contract like a connection for different a CFD, would be, automatically exempt, which is great. Right? You know, say that the projects that we think we need for the you know, to keep the capacity.

And this is to Joe's point. Right?

So if you've got that contract for difference, the chances are you've taken FID on that project.

You are gonna be building it. Contract for differences actually do have various, checklists and things that you have to meet in order to get the contract in the first place. You have to have planning. You have to have a grid connection.

You have to meet certain milestones and there are penalties if you don't connect. It's actually probably better designed than some of the contracts that we use for connections in in a quite an unironic way.

Yeah. There's perhaps more kind of diligence on that. So so those are the really big additional exemptions.

I I guess, Ed, you can probably put a link to the the letter. Absolutely. So so by all means, could go away and read some of the footnotes, but but those are the biggies. So so from that perspective, I guess, what what I think good looks like is we're already doing some of it because we're protecting that kind of, risk against investment hiatus. We're sort of we're moving at speed. We moved at speed already. We do probably need to get to this point where we pin down the pots, and the that needs to happen sort of ASAP.

The worst case, I think, would be if we carry on drafting and redrafting pots, and it overlaps into the point when connections reform has technically been implemented because you could get to a scenario where NISO are asking customers to sort of put their hand up and say, are you ready? Are you gate two ready? And they haven't declared what the goalposts are, you know, so they could almost do a sort of wait and see. We'll see who applies to us, and then we'll decide what our final numbers are. I think that would really, really impact on industry confidence. So setting the numbers, acknowledging that they won't be a hundred percent, and therefore put some attrition in.

Okay. And following on from that, one of the one of the things that I actually would really like to get out of the connections reform is, just transparency of rules. So investors hate uncertainty as we everyone seems to say or everyone knows.

And grid connections is quite has historically been quite a grey thing. There's always grey everywhere you look. Right? Whereas with this grid reform, we actually can really detail out a lot of the rules that govern things like, you know, what we're talking about, like, the pots.

Site. There is a clear plan, a strategic plan, everyone knows by everyone's playing by the same rules. The same with like what what, you know, how do you, I know we're going to come on to this, but how do you change the technology? Or how do you how do you, amend your connection?

How do you delay your connection? Like, all of those rules need to be very clear so that everyone is able to play by the same rules. I think in grid connections, there's always been, a little bit of those who have the in information, or or those who, are able to just talk to the networks often get a better outcome than than those who don't know the rules.

And I think maybe maybe one thing that kind of strikes me is that if we if we do the eighty twenty rule and we kinda set out what it looks like, from day one, day two, information changes, and all of a sudden we might have more demand in an area or a certain technology might be performing better or a certain technology perform might be performing worse. And, yes, individuals might choose to change their connections, which which, as Joe says, we'll we'll come on to. But is there is there kind of an allowance within kind of the grid process to say, hey. We're we're we're racing towards twenty thirty, but, obviously, in twenty twenty eight, we're gonna have a little true up. We're just gonna make sure that, actually, like, we just need to tweak the numbers. Is that is that baked in, or is that kind of, not really thought of?

It's so it's it's really, important point because it's not currently baked into the the the baseline proposals, but it is one of the sort of, like, alternatives that's being worked up to say, actually, exactly, you know, great phrase. You know, that kind of true up idea of reflecting has has this worked? Do we need to amend some of those levels? I guess the counter to it is, that realistically, we will set some of these pots, and that will prompt, you know, investment decisions, hundreds of millions of pounds spent on, you know, really quite specific assets.

So the the transmission owners, for for example, you know, if any of the network owners kind of need to be told this is it. Go go buy stuff, build stuff. You know, not this is it for now, but we might tell you to stop in eighteen months' time. That kind of mixed messaging in the past has been really detrimental to the speed of delivery.

So so I think perhaps it's more, go now, build build big, build fast with with certainty.

Maybe there should be a reflection exercise point, but that's a kind of retrospective reflection to see if there are any minor tweaks as opposed to a a big hiatus.

So if not in twenty twenty eight, when does when does grid connection reform have its moment of reflection?

Well, I think the Christmas twenty twenty five.

Yeah.

Christmas in a year's time, we we might we, in theory, we will have the answer to what the sort of, what the new cue will look like us.

I I think NISO have been very clear. They're only the great grid reordering is only happening once. It's a one off exercise where they're gonna change people's queue position.

And I and I think that is a lot of that is because that if you suggest that you might change it again in the future, it creates a lot of uncertainty for investment, which Catherine just said.

But there is something they're doing, which is the strategic spatial energy plan, which is a follow on essentially of the Clean Power Plan two thousand and thirty. And the idea of that is to is to align the connections pots or the, you know, the connection process with, the planning authorities and and what people are actually going to be given planning for, and trying to make sure that what what the local authorities and and government, approve to build can can be connected to the grid. Right? So there that that in a sense is a true up, but it's more of a it would be more of a pivot than a than a reconciliation or anything.

Perhaps the SSEP is more of an enablement of the Clean Power twenty thirty plan that gets set. Yeah.

It's well, it's sort of like a an addition.

Right?

Like, it's gonna It's the next generation.

It's the next generation of the Clean Power twenty thirty plan. Yeah. Exactly.

Then the and the other thing as well is It'll hate it.

Yeah.

Nissan are there is some flexibility in the in the reforms. Right? So, with these pots, the Nissan has been very clear that they can you can move capacity between adjacent zones.

At the moment they say it has to be like a transmission to transmission zone or a distribution to distribution zone. It can't be transmission to distribution, which potentially is an oversight.

But there is that flexibility there. And I think that's really important because as you say, if we if if one area, for whatever reason, they've got it a bit wrong and it there's not as much been that can be built there, they need to be able to shift that somewhere else in the country. Right?

K. And and so we now have this eight twenty rule, really clear plans, twenty thirty. That's all gonna be absolutely fine. Are we have we got a tsunami of projects at twenty thirty one that are gonna be waiting to build? Like, how how do we deal because if I'm building a project to twenty thirty one, I need to be planning for it now.

Yeah. I mean, I think so so so realistically, although perhaps the numbers are a bit misleading, although we talk about a clean power twenty thirty plan, the exercise that, you know, Joe's great grid reordering, that's happening once really is setting a queue out to twenty thirty five. So it's just got a first tranche of projects going to twenty thirty, and then it's got a second tranche going from thirty one to thirty five. So I think you'd be legitimately concerned if you were saying, well, I was thinking of building a new nuclear station in twenty forty, and I'm not gonna be in this plan.

Although there are some designations for that.

So There there are I was gonna say we do Long lead items or long lead projects, sorry, can be designated so that they get given a grid connection even though it's past twenty thirty five.

So there's definitely not a cliff at thirty to thirty one. You know, I think that's that has been thought about, and the proposals are really quite sensible.

There's there's definitely more detail to be worked out about at the moment, there might be some room for sort of some gaming. You know, it kind of looks like it might be beneficial for some projects to sort of say, yes, I want to be in the twenty thirty tranche knowing they're unlikely to quite make it, but it might make them more likely to get into the thirty one to thirty five tranche. So that kind of there will be transitional kind of edge case issues, I guess.

And and something to be understand is that the Nissan has purposely, decided to create a queue up to twenty thirty and then a queue up to twenty thirty five. And the reason they did that was, partly to do with attrition. Right? They were trying to say, we're gonna need, some of those projects that are current are gonna be given a twenty thirty one to twenty thirty thirty five, as they develop may actually be able to come forward. And so when other projects delay or terminate in between now and twenty thirty, those projects in twenty thirty one and onwards can come forward. They can be accelerated.

I think my concern over this is that it again, going back to, I don't think it, reflects how development business models work.

It's really hard to accelerate projects. If you've got a connection date of twenty thirty three, you will plan for a twenty thirty three date. Right? You you planning only lasts a certain amount of time in in certain in some situations, although from what I understand, I'm not a planning expert. From what I understand though, you can sort of get, longer than the the typical three years if you want.

But generally you if you've got a later connection, you'll wait to put planning in and you'll, and then you'll, you know, you'll plan your procurement around that. To then accelerate is really difficult because first of all, you probably will only be able to accelerate when the project delays and the project is only going to delay when it has exhausted all options, to to keep the connection date it's got. So it will probably delay at the last minute with maybe, I don't know, a year, two years out from its connection date. You're then asking another project to go.

You're going right. Come and connect in two years' time. They particularly at transmission, they've got to do procurement. I mean, a long the supply chain at the moment for transformers, four hundred kV transformers is like three years.

So I think it just it it's a lovely idea, but it I think doesn't quite appreciate the practicalities of accelerating a project.

But you're a little bit damned if you do damned if you don't. Right? So on one hand, you're saying it's really hard to accelerate stuff. On the other hand, if you kind of front load the queue knowing that some stuff's gonna drop out, you don't know which bits are going to drop out. And so you're kind of you're giving this great big chunk of work near term.

So it feels like Oh, I didn't.

Oh, I I As as well, as in Nissan, don't win.

Oh, yeah. Yeah.

Nissan. Or the or the or UK peers. I I I kind of disagree in the sense that I suppose what we what we see now is reality, you know, that there's that Joe's explained how why it's so hard for a developer to accelerate, and developers sometimes delay. I think it's very important to recognize that transmission owners and and network operators also delay.

You know? So we all put together a plan that says, great. You know, in twenty thirty three or twenty twenty eight, we're gonna connect this project. But, you know, often those network parties are are fighting for the same supply chain.

You know, they've got some of the same constraints in terms of resource and workload, and and it's almost inevitable that time frame slip. So I think, actually, you know, there's almost like a level of saying, if if you if you took those pots and you said, oh, actually, I think we need to inflate this by twenty percent, twenty five percent. So we're gonna basically let a hundred and twenty five percent of the kind of theoretical pot capacity into the queue. We're gonna study all the reinforcements and okay.

So, actually, we're now building a hundred and twenty five percent of the stuff we thought we might have to build by twenty thirty, but twenty five percent of it's probably gonna be late anyway.

And which which is why I think you have to look at it as the status of those projects. Right? Projects that have planning are more likely to be built than projects that don't, and projects that, have a financial investment decision are almost certain to be built. Right? So it's just acknowledging the risk profile of their different projects and building that into the to the pots and the how you're designing the queue or how you're managing the queue.

I think to one thing Catherine was saying earlier, the kind of the phrase really quite sensible.

I think if we can apply that to any part of connections reform, I think we're gonna be in the right right now.

People have different opinions of what really quite sensible is. Right?

Okay. Okay. Good.

So I'm gonna move us on to, a topic that I think comes up quite a lot, and I think we're potentially gonna see a lot more of, which is amendments to queue. So let's say I've got a battery storage project. It's fifty megawatts, but I'm really excited about the prospects of colocation with, say, solar. What happens next?

So shall I go first? Okay. So, of the I sat in sixty working groups for, Grid Connections Reform, which was the highlight of my of my life.

One of the discussions in that, which, took quite a few working groups was, the talk of a significant change and a material change. So a significant change is something that requires a modification application, a mod app, I. E. You have to apply to the network for approval to change your connection.

The other thing was material change, which is a change to your connection, which re which requires you to be modeled, and we're talking about the assumptions that are made when we plan a network. So, requires your project to be modeled, at the back of the queue. So with lots of other all the other generators in front of you.

And, there was a lot there is a lot of discussion still ongoing about what, is a significant change or what rules are, what would require a significant change and what would require a material change. And I'll focus on material change because that's the more important one because it it puts you to the back of the queue.

NISO are planning to issue a a guidance, and they plan to do this before connections reform is implemented in next May. So that document will hopefully be clearly stay, if you do this, this or this, you know, you will be modeled at the back of the queue.

Yeah. And I suppose the, it's great wording, isn't it? I know exactly that sort of the history behind all these words. I think I you probably almost want to call a a significant change a tweak.

Yes.

Okay. One of them's a tweak. One of them's a material change. But, but I suppose also just before that guidance comes in, Joe, before that kind of terminology is officially used, the current process is effectively that anyone who holds, I guess, we're we're sort of focusing at transmission here.

Anyone who felt you know, for a large scale project, holds a transmission connection agreement, they have to, they apply. They do this modification application to make a change, but but they're kind of taken on a case by case basis. And, and the the system operator and the TAs evaluate those, and you could you could put one in tomorrow. And, as we record in December, and and they would have to evaluate what the what the impact was of adding, say, solar to your project.

And then you might not go to the back of the queue. That might be perfectly possible. You keep your connection date. And so, you know, completely understandably, there is a huge amount of change going on because lots of people have looked at these draft pots and things and thought, well, I can sort of see the way this is going.

You know, maybe I I need some other technology to kind of try and evidence that my project is needed or to help my business case. So there's huge amounts of of mod ups being submitted or or or variation agreements. And one very practical point is that you've got a whole lot of network operators who were just going, woah. Stop.

You know, I've I you know, I've got to get my network ready for this massive change coming in connections reform. I can't do that if I'm still having to churn the handle on, you know I think I was with Scottish Power, transmission, last week at their connection summit. They said they had they were receiving three times the volume the normal volume of of modification requests at the moment. And they they just put out a plea to say, you know, to to the regulator, you know, we can't carry on doing this.

So I think it's very likely that we will see, some kind of, what we call transitional arrangements, but essentially, a a a a kind of drawing a line in the sand that says, right, now everyone has to stop. You won't be able to put in mod apps or carry on changing until connections reform has been implemented to give the actual the engineers studying the networks a bit of breathing space. So I think we might be looking at a very limited window for people to play around with their connection.

So so so, Catherine, one one thing just before we go on any further, I'd really like to get, some clear examples around a significant change versus material change.

Okay. So if we think of that kind of significant change being the sort of tweak, so that example of that would be a, a generator. Perhaps they're a transmission generator. They have a five hundred megawatt solar farm, and they've got five hundred megawatts of tech, which is the export capacity.

They want to modify that so that they're now going to be a solar farm and a wind farm. So they're gonna still keep their five hundred megawatts of tech because they're not gonna they're gonna kind of, balance that behind the meter. But they're gonna some of their solar, they're now gonna build out as wind. That would be considered to be a kind of a tweak effectively.

They can just submit a modification application, and they will effectively keep their place in the queue.

By comparison, if you're a five hundred megawatt solar farm and you decided what you wanted to be was a five hundred megawatt battery, they would need to, you know, that would be a change in their input capacity. So so they haven't got they haven't applied for any kind of capabilities to charge that battery.

That will need kind of restudying, which is likely to take them to the back of the queue. So that kind of a fundamental change in technology, which also triggers a change in your input capacity or export capacity is a material change.

I just it feels it feels kind of odd, right, because going from solar to wind will definitely change how that thing performs and will definitely change how it will impact the grid.

Well, you would disagree with that also.

Well, not quite. But no. You're exactly right because the problem is, as this conversation shows, is it's a gray area. And it the the general term used is, does it have a detrimental impact on other users?

Which is a really vague way of explain of thinking about it and basically means that you, as a developer, have a discussion, you know, that sometimes might be quite heated with the network engineers saying this does or doesn't you know, you're trying they're trying to explain this doesn't have a detrimental impact on the users. They're going, well, maybe it does. So it it it's and this is where I was trying to go back to. It would be helpful to have rules, very clear rules and clear guidance because it would stop the back and forth and stop developers feeling like they are being mistreated or even worse, is one developer, one project being treated differently to another.

And that at the moment, there is a real risk of that just because the rules are not defined. So different, people may have different, subjective opinions of how what is material change on the map. Mhmm.

And and just, just before we move on to the final two questions, I just hope to get an idea, like, of that queue that we've got, is it kind of one percent that's coming to kind of tweak things? Is it fifty percent? Is it a hundred percent? What's what's your what's your gut feel?

Well, I mean, I think there are whole swathes of the queue, like, for example, the battery swathe, you know, so people who had standalone storage projects, I would say, are the biggest, you know, they're likely to be the biggest losers from connections reform, you know, and and therefore, I think it's understandable that there's the maximum amount of kind of tweaking or radical redesign that's being considered in that. And and the battery part of the queue is a really big one. So I'd I'd go up in the kind of, you know, forty, fifty percent of the queue is looking to potentially do different things with their connection.

Yeah. There are there are monthly stats on connections, which, the Nissan publishes and ENA publish. We'll we'll have to look at that when it comes out for the next month. But, yeah, I I agree.

I think it's gonna be a higher than historic amount because there are a lot of people who are trying to work out how they're gonna set themselves up here for connections reform, and whether that's changing their technology or adding technologies or, you know, even, just trying to modify their date. I'm not entirely sure why you would do that, but, you know, at the moment with because grid reform is gonna make you do that anyway. But, you know, people are just trying to work out how they're gonna react to this. Yeah?

Okay. I think that's really useful for people who'd be listening to this with projects trying to just understand what the landscape looks like. It changes so quickly that unless you're in it every day, it's so hard to kind of actually really understand how it'll work. So Yeah.

That's been really useful. Onto the final two questions. Now I gave you a choice. We usually ask people to Wait.

Oh, no. I hadn't thought about that. Sorry. I interrupted that.

So so so I gave you a choice. You could either choose to plug something or you could, put forward a contrarian view.

And it's it's one each. So, Catherine, would you like to go first? You can either plug something or bring forward a contrarian view.

I am gonna plug something, which I realize is the easy choice, Ed. And it's be because it's something which maybe sounds boring, but it's super important.

So as we're recording in December, the, Ofgem have released yet another consultation, and which I know is not gonna be popular news to people. But this one is, you know, I think had a great chat with Ofgem, and they sort of described it as, an opportunity to even the scales, you know, a reflection of the fact that connections reform has made things really quite difficult for developers and that we do have this quite unbalanced landscape where, you know, you sign a connection agreement with a a d a network operator, that sort of, you know, where you hold all the risk, they're allowed to change it.

You know, we're we're introducing all of these kind of higher bars, so you have to kind of additional hurdles you have to jump through. And yet the kind of landscape for the regulation of the networks has remained really unchanged. So like I said, you know, it wouldn't surprise me if we we end up delivering a lot of these network reinforcements late and things like that. So people's connection dates slip back.

This consultation is about some pretty punchy measures that could be introduced like, you know, liquidated damages on network operators for being late, you know, you know, some quite significant regulatory commitments to make, you know, to to really hold network operators to account. So it's a sort of it's called the end to end, review, and I'm sure we can pop a link to it. But, it's, you know, it's it's almost like a tell us your pain, you know, and I feel like a lot of developers have a lot of pain. So, you know, it's a group therapy session for everyone.

Okay. Great.

That's my that's yeah. So we all need a bit of group therapy probably, and Ofgem are offering to host it. So, so reply to Ofgem.

That's my my Hundred percent.

Great great plug. Joe, over to you. Which way are you going?

I'll go for a contrarian view, I think, which is always risky. But, I actually think on the on the theme of consultations, I actually think we potentially, haven't had enough consultations.

That is a controversial opinion.

And, there is a, you know, at least one more con consultation we need, which is on, pots, the number the and the pots that the government the plan that the government is about to issue.

It's not being consulted on, and it needs to be consulted on. And therefore, I would love another consultation.

That will be contrarian. Congratulations. That's a genuine contrarian view. I love it. Okay. Well, both both of you, thank you very much for coming on.

You've been fantastic guests, and I think people listening in would have learned a huge amount. So thank you very much.

Thanks for having us.

Thanks, Ed.

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