Can Regulatory Reform Unlock the UK's Clean Energy Future with Georgina Mills (Ofgem)

Hello and welcome. Today, we're joined by Georgina Mills, who is the director of energy systems management and security at Ofgem. We cover some of the key changes being considered in the consumer market. So should we be changing standing charges, removing them completely, or should we be changing unit rates so that we encourage flexible behavior from consumers? For the battery heads, you'll find the second half much close to home. We talk around how Ofgem is working with NISO to bring skip rates down for battery storage so we can get the most out of the storage fleets in GB. Let's jump in.

Hello, Georgina, and welcome to Transmission.

Great. It's good to be here. Thanks for having me.

Of course. Our pleasure. And, as always, let's get started with who are you and what's your role within energy.

Great. Well, my name is Georgina Mills. I work at Ofgem, which is the, regulator.

My die my title is, director of energy systems management and Security.

I joined Ofgem a year ago and I've got quite a broad remit.

It includes network charging for electricity and gas markets, it includes security of supply for both electricity and gas, It includes day to day management of both the electricity and gas markets, including the market rules that we have responsibility for in the wholesale market, and it also involves system regulation and management of the what was the ESO, now the NESO.

Okay. Very good. So actually a really broad remit across Yeah. Those parts of the energy market. And actually to give, listeners a little bit of context, what is your sort of history before energy?

Yes. So, I'm relatively new to the, energy sector, although I have done a bit of a full circle. I started my professional career as a government economist back in the Department for Trade and Industry in an energy team, and, I joined government wanting really to be a competition economist, so then moved across to the Office of Fair Trading, spent a few years there, and then moved back into central government focusing on regulation, moved into the aviation sector, and did a really interesting project to completely reform the legislative framework for airport economic regulation, but working on the government side. And then decided actually I wanted to go into working for the regulators. So I spent ten years in water working as a director in the water sector at Ofwat.

Worked on the price controls as well as the retail market there. And then I spent eighteen months working and living in New Zealand. My husband's a Kiwi, so I went there for kind of family reasons really and spent eighteen months working at the Commerce Commission, which is a multisectoral regulator and a competition authority.

And then a year ago, came back to the UK and started my current role at Ofgem.

I feel like I I kinda have to ask following that. How how sort of how transferable are the sort of learnings from Yeah. From one sort of regulator to a to a or from one sector to another?

Yeah. So some things are very similar. So network price controls, there's lots of similarities.

I think, working in retail and the code modification process, actually, I think energy has got some lessons to learn from water.

I led the COVID response when I was at Ofwat, and Ofwat had more flexible powers to make quick quicker changes to the market code. So we were able to implement a, liquidity support scheme very quickly in response to that crisis. So, that was quite interesting actually.

There are some big differences. You don't have a system operator in the water sector. You haven't got this big integrated network. You've got a series of sort of unconnected at the moment, sort of vertically integrated regional monopolies in water.

So that feels quite different. I I think as well, historically, there's been a greater sort of role and use of markets in energy as well compared to water. They've tried to use some markets and competition in the water sector, but I think the nature of energy is that you can kinda use those a bit more in that sector. So some big differences, but also some learnings, I think, and some similarities.

Yeah.

I think it's very good for the sector to have, influence from outside. So sometimes we can be a bit sort of a circular reference, with some of the same ideas. So very interested to get into today's conversation. And just to get to the the really key part of it actually, which is around consumer bills. So this question must come to you all the time, which is how do we get consumer bills down?

Yes. And there is a huge, huge focus on consumer bills. I think hopefully a bit later on we'll talk about some of the work we're doing including on consumer research to better understand some of the very strong views that we've been receiving from consumers.

I would say if anything was easy or obvious, it would have already been done on the consumer bill. I think there's such a focus there. I think if you look at the total energy system and the the the costs of that system, it is sort of built to meet peak demand to provide security of supply at peak consumption, peak demand points in time.

So I think, potentially, there are some avenues in terms of if you can try to shift some of that peak demand to kind of other times of the day. Does that mean could that obviate sort of the need for some of that network build, that kind of that that investment that we're gonna need to see in the in the next few years? Because, it's not just net zero. We're gonna see a huge increase in electricity demand from consumers as that wider economy, heat transport, all electrifies. So there's a lot of investment that's needed up and beyond two thousand and thirty. And if you think about, actually, can you shift some of that demand away from peak, particularly, like, sort of non domestic demand, could you then sort of would that lead to a smaller system being needed overall? So I think there are some really interesting questions there about sort of consumer led flex and whether some of our regulatory tools can kind of support that and reduce that sort of total system need over time.

Mhmm. And if you're particularly interested in this space, we have just had the flexibility roadmap was published, I think, in June.

Yes. Yes. Okay. Yeah. Yeah. Yeah.

And if you wanna listen more to that, we had an episode with Marzia, also from Ofgem, which was a few months ago. So check that out if you wanna spend a little bit more time thinking about it.

That is an excellent podcast. I've listened to it. I would definitely recommend it. Marzia is very engaging.

Very good. Very good. And also perhaps similar to yourself. She brings lessons from other markets as well.

She comes from Yeah. Californian background. Right? So I think there's a a huge number of lessons that can come from borrowing from one market or one region to another.

Okay. So on consumer bills, lots of focus on it, but lots of the easy wins have been done. You're looking at other ways of potentially changing how billing and cost recovery works, in the interest of consumers. So you recently launched a review on the allocation and recovery of energy system costs. What's the aim of that review, and why are Ofgem looking at it now?

Yes. Yeah. So I think I mean, this review is really going back to first principles to think about how should these system costs going forward be allocated to and recovered from different types of customers. I think we're seeing huge shifts in the energy system.

So on the supply side, we're seeing a shift to renewables and the kind of that the cost makeup of those types of technology are different to the kind of fossil fuel heavy technologies we've seen dominate the grid in in the past. And I think on the demand side as well, we're seeing customers use techno sorry, use technology and sort of use energy in a different way, but we're also expecting to see a big increase in demand for electricity. So I think and coupled with that, we're getting very strong views from consumers. Over the past few years, we've had unprecedented amounts of consultation responses, from consumers talking about not liking standing charges.

They think they're not fair and they don't like the fact that they don't have then control over their energy bill. So I think given all of that context, we thought now is the time to step back and think about from first principles, how should these costs be recovered from consumers in the future.

The call for input we've published is very open. It's very explorative at this stage. We're not putting forward specific policy options. It's the start of a very open conversation with the entire sector about how should these costs be allocated and recovered from consumers in in future.

Mhmm. Oh, and one, outcome of that that I saw from early publication was you you looked a little bit about zero standing charges. So this concept is just scrapping them. Yes. Was what how how did that go? Was it, something that consumers would have liked or was or like did was was it well received?

Yeah. So kind of the the the cost allocation recovery review is separate to the work that's going on in standing charges, and we've published something recently on that as well, looking looking at whether we should mandate supplies to offer a lower or a zero standing charge option as well. And, we're also conducting some trials looking at alternative approaches to, charging customers. For example, we're looking at an approach whereby you split the standing charge into a standing charge and a kind of a time of use charge.

It's kinda based on consumers' consumption at peak. And that trial is aiming to understand kind of if consumers face this incentive, are they how are they gonna respond to this, and what's their experience of kind of that alternative approach? Because at the moment, we have this two part tariff mainly. I know there are some other options out there, but generally, energy pricing comprises a two part tariff, a standing charge and then a volumetric charge.

And I think we are really interested in looking at alternative approaches to recovering those costs from consumers.

And it's it's part of it. You know, you say, there's a standing charge. Everyone who has that connection pays that standing charge. That's frustrating.

If, let's say, you have solar panels and an EV and you run your solar into your EV and you think, well, I didn't actually import any energy on that day or, that house was empty for a week because I was on holiday, why am I paying standing charge for that? I didn't I didn't I didn't do anything.

Yeah.

And that is a real dilemma because even customers that might not make a lot of use of the energy system, because that system is built to service peak demand Mhmm.

If you're contributing to that cost and that kinda total size of the energy system, is it fair that you should pay some of some of those fixed charges to kind of running that system? So there's a real dilemma there. You want to incentivise delivery of net zero. You want to incentivise the adoption of these alternative technologies.

But at the same time, you want to sort of understand what what what's fair in terms of kind of if you're contributing towards a system cost, should you pay for that? So there's lots of trade offs. There's no perfect solution to this. I think there are there are trade offs.

It it is very interesting because in a way that the standing charge because they're quite static, it's, in some ways similar to, like, tax that is is kind of, like, not progressive. It's the same thing for everyone. And, actually, there's, to your point, the the way that we get cost down is we don't have to build as large a system with as many sort of fail safes and as much spare capacity on the system. And if we can get consumers to be influenced by the prices in the market, then potentially we can bring down that additional capacity.

Yeah. And so that to me sounds like, perhaps you're saying, well, standing charges, they they don't really give any signal whatsoever. They just say you've connected for a day. Whereas a time of use tariff is saying, it's more expensive in the afternoon than the morning, so please run your washing machine in the morning.

Yep.

That feels like it is trying to move consumers to the right time of day even if not necessarily all of them would react to it.

Yeah. There are definite benefits. I think we've we've spoken to other regulators about what they've they've been doing, and we have seen time of use rolled out in some parts of Australia. And there's actually been some sort of negative reactions to that, I think, where consumers haven't realized that they were being put on time of use tariffs or they didn't have the information or the ability to respond to those.

So I think in principle, they sound very sensible, but I think in practice, you need to think about are the consumers able to respond to those signals, and do they have the information and the ability to do that? So, yeah, there are trade offs. We're not putting forward any specific options in our call for input. We literally want to talk to the sector about what are the potential options here that we should consider.

We haven't made our mind up at all.

This feels like a, esteemed, market, economist meets, someone, a parent on a school run who just gets home and thinks, Christ, tell me to use tariffs. I'm I I just need to I just need to do just get on with this, please.

My parents are never not gonna have their dinner at five thirty. They're never never gonna not wanna sort of make a cup of tea during EastEnders. There are some sort of patterns that you just never will shift.

Okay.

So how are you looking to explore those options? So when you, have kind of have the responses in and you get this idea of whether people like, standing charges or unit rates or time of use tariffs, how does that turn into something that then the, suppliers actually have to act on?

So in terms of, how we're gonna look at the options, in our cost allocation and recovery review, I think we've identified five principles that we want to assess all the options against. So we've got efficiency, including over the longer term. We've got fairness, net zero, economic growth, and practicality. And so what we've done in the call for input is sort of sketch out an assessment framework and seek views on, are these the things we should be assessing these options against?

Because are these the kind of key trade offs, that we're gonna need to to consider? And I think in terms of thinking about how, changes in our cost allocation and recovery approaches feed down to kind of consumer bills, that's a question that we've asked consumers and and suppliers in particular as part of the call for input. Kind of if we, for example, were to change some of the cost allocation methodologies, kind of, would they then feed through down into sort of supplier tariffs or not? So I think that's an open question that we need to engage with the sector to better understand whether if we make as the regulator changes, will they flow through down into kind of bills?

Yeah. And I feel like this conversation up until this point, because I'm I'm a I'm a markets person. I like flexibility.

I feel like I'm automatically gonna be on the side of time of use tariffs.

But one thing does stand out to me, which is that, let's say I have a house with a roof. I could buy solar panels, and I could buy a battery and or I could have an EV. Kind of the same thing. Yeah.

And I could feasibly run my house from, from that sort of self generation, and I could almost avoid so much of the of the sort of unit rate over the course of the year. And I could just turn up on December the third Yeah.

On a particularly bad solar day Yeah. And say, oh, actually, oh, by the way, grid, I need, a lot of energy Yes.

On that one particular day.

Yes.

If we were to sort of move away from standing charges, it's almost like I've not been paying my dues all year.

Yes. And I've just rocked up for one day, and I'm gonna sort of bring in as much energy. And it feels Yeah. Does that does that feel is that the type of thing you're also thinking about that there there almost feels like there needs to be some element of insurance premium in this?

Well, I think that comes to sort of how your fixed cost should be recovered from different types of customers because that type of customer you were just describing, the the system will still need to be built to serve their demand at peak on a Dunkelflauter type scenario day where it's kinda there's no sun and there's no wind.

So I think that comes into the kind of the fairness and the efficiency question, kind of should that person be able to avoid those, those charges all year if the system has been built to kind of serve their peak demands? I think that that's some of the that is one of the trade offs we are gonna have to explore as part of this because that kind of customer is doing their bit for net zero as well, and there's that trade off that we're gonna have to explore as part of this assessment framework to try to sort of understand the scale of the trade off. Like, what what does that mean in terms of when you start to put numbers against it? And what does it mean for people's propensity to sort of switch to those types of technology as well? So none of this is easy. None of this is, yeah, none of this is easy. It's very challenging.

Agreed. And on the on the side of, that particular customer, I think that some people, when they think about standing charges, feel like it's kind of sometimes money for nothing, which is why it doesn't really surprise me when you said, oh, there's there's there are people who are sort of making this clamoring to look for zero standing charges because it just you know, why am I paying this money for nothing? But it perhaps feels like it needs a bit of a rebrand, which is like, this is more of an insurance product. You know?

So if you want to have the ability to connect to the grid, importing or exporting, you kinda have to pay to be part of that. Mhmm. And maybe I think if you pitch it like that to people, they would understand. Because people are very happy to pay an insurance premium for their house.

Yes. They don't expect the house to burn down every day. Yes.

Yeah. Yeah. Yeah. Yeah. And I think the the engagement we've done, the consumer research we've done, where they've said that they just see selling charges as unfair, we then did an online experiment where they were giving a bit more information.

It didn't completely change everyone's mind, but you then did see, a slight reduction proportion of customers that were saying it was unfair once they started to understand, what it was paying for.

But there is also this sense about consumers want simplicity and that kind of ease like, that that control over their bill as well. So, you're right. Sometimes, kind of, is it, like, how these things are described? Like, when you look at other sectors and everything has a fixed cost and a volumetric cost and sort of different sectors take different approaches to kind of recovering those costs.

And things like subscription based models, they kind of bundle those kind of costs into a subscription based charge. Things like Netflix, you kind of pay. Prime, you pay for kind of an amount of capacity over a month. Mobile telecoms is is like the same thing.

And And then you'll kind of have extra charges when you go above and beyond that. So they don't differentiate between this is recovering my fixed cost, this is recovering my volumetric cost. They just have a, like, a monthly subscription charge that covers both. So I think we do need to look at other sectors to kinda look at those alternative approaches and think what is appropriate for the energy sector.

Fascinating space. And sometimes I think when in consumer led flexibility, sometimes people can think, oh, you know, it's only just, you know, it's just number fourteen on the street. They they do this, but nobody else does it. And and it comes down to, it's one gig here, one gig there maybe, and the power sector's forty gigs, so it's only a tiny fraction. I think just to give people a bit of context, the in the the plans out until two thousand and fifty in terms of some of the flexibility, the consumer led and demand led flex potentially has something like eighty gigs of flex in it, which is one of the recent numbers. That is quite frankly, like a mind boggling number, in the sort of the demand in GB at the moment. It's somewhere between, say, twenty five and forty gigs.

So you're kinda telling me, oh, actually, there's gonna be double that amount of flexibility potentially coming from consumers that maybe whether that's batteries, EVs Yeah.

Shifting, storage heaters. So the the number is massive. Mhmm. And, you know, to the extent that people are kinda wondering, well, look, why are we why are we bothering with this? Why are we asking these questions? I hope that kinda gives a little bit of context as well. No.

It's huge. And I think there's there's also debates, isn't there, about to what extent some of the consumer, like, domestic consumer led flex. Is it going to be, like, you're consciously shifting your demand, or is it gonna happen? Is technology just going to do it for you?

So where you've got batteries and EVs, technology can do a lot of that heavy lifting. I think we've had some debates internally about consumer led flex and kind of how much of it is gonna be sort of the technology will do the heavy lifting versus sort of consumers actually actively thinking. My sister-in-law lives in Australia, and she does her washing overnight kind of. She she's already kind of shifted her behavior.

So that is an interesting debate kind of where where are those shifts gonna come from, what's gonna facilitate that, and the consumer, how active are they in that role? And I've I've heard very different views on this.

Yeah. So I know if you talk to consumers about their EVs today, they bring home a brand new EV. You say, oh, do you would you mind if I borrow the battery in that EV to charge it up and charge it down? They might go, no way.

That's my brand new EV. I never wanna see that touched by someone outside of, my control. But then you kinda fast forward fifteen years, and you say, well, I'm buying, like, a a fourth hand EV that's already done a hundred and fifty thousand miles. Maybe I'd be very happy for someone to pay me a hundred, two hundred pounds a day to kind of charge the battery out.

I mean, that's maybe far too much money. But maybe I'd be very happy for someone to pay me five pounds a day to flex it up, flex it down because there's not such a premium thing anymore. So, yeah, I think we spend a lot of time internally trying to just work out that eighty gigs. Is it, like, genuinely eighty gigs of daily flex, or is it you know, how does that all work?

So, a fascinating space. Move us on a little bit from standing charge and unit rates, and the world of consumer flex onto another part of your remit, which is looking after, Nissan's performance.

And, obviously, Moto Energy, we spend a lot of time thinking about battery storage.

Yes.

And in particular, battery storage, one thing that batteries provide is flexibility to the system in terms of charging or discharging in that last hour before delivery and often dispatched by NESO's, the National Energy System Operator's control room. Yeah.

And one of the things that has been known about in the sector for a long time is this kind of concept of skip rates. So when batteries are a cheap option, but they're overlooked in favor of something else, and that is sort of a a story that's been rumbling for some time in the battery space.

How does Ofgem think about that problem?

How is it changing?

So I think we would agree, this is an issue. It's very important, and it needs to be fixed quickly.

So in our role as regulator of the Naso, we recently published a draft in final determination for the business plan that we're in at the moment. We call it BP three.

And battery skip rates was the issue where we got the most sort of, like, the vociferous response really from stakeholders.

So what we initially said was that this is important. It's gotta be fixed soon. And what we want to see is parity with other technologies. That that's what we want to see from Neezer. We wanna see a big improvement this year. By the end of the year, we wanna see parity with other technologies.

I think stakeholders came back and said, that's great, but we also think we want specific metrics and and specific numeric targets.

So what we said in our final determination is, yeah. Okay. That's fine. Yes. We need some specific metrics and specific numeric targets.

So Naso's currently working with industry. It's published its roadmap to agree what the metric should look like so that everyone's agreed there kind of aren't any wheezes in the way it's measured, and then it's going to agree some numerical targets with the sector as well. But I think it has taken a bit of time to really focus on this issue but I think we are seeing some improvements in terms of the focus on this issue now. I think what we also need to see is systems improvements and better data.

So NISO do need better data in terms of understanding, for example, battery charge levels.

And we're sitting on a, I shouldn't say we're sitting. We have a code modification with us at the moment for decision, which, if we approve, will enable, NISO to have much better oversight of charge levels. And that should provide much better certainty in terms of when it's dispatching those batteries. It's got much more confidence in terms of, is it fully charged? Is it nearly empty? Yes. So that should help too.

And for fans of numbers and letters, it's g c one six six. Yes. Uh-huh. And and sitting, I think, is a fine terminology if if it is a panel making a decision. Right? You sit on panels and panels make choices. So I'm I'm okay with sitting.

Sitting implies we're taking our time, but we think this is an important code modification, so we're treating it as a priority.

Before we talk a little bit more about that, that particular topic, I think one of the areas that this is most important for is for an investor outside. Let's say, you know, company x. They're looking at the GB space Yeah. And they go, I want to put money into battery storage space.

I can see it's important. I can see that they've got between five and six gigs, of battery storage, and I know that they want to get around forty to fifty gigawatts by twenty fifty, let's say. Yeah. The the the number varies a little bit.

It can be a bit higher. The motor number's a little bit higher, but other ones are a little bit lower. And and that number to me is somewhere between twenty and twenty five billion ish that needs to come into the space. So a lot of, investment that needs to be attracted to to to the space.

For that group, they would hear this and go, okay. I can see the skip rates. I can see the data.

Yeah.

How do I get confidence that BP three is going to go full circle, and this isn't just gonna kind of, like, fall off somewhere and and just be forgotten about in some way. Because for the, you know, twenty five billion is, a lot Yeah. Of of of investment that we're trying to attract.

So I think as the economic regulator for Nezo, it sets its business plan. We set our expectations as part of that final determination process, and then we hold them to account for that. So we give them feedback in year, but we also do a formal end of year assessment as well. So we we have been very clear that this is a very firm requirement and expectation on NISO for this year.

So we will be holding them to account as the economic regulator. So these things don't get forgotten. They get set in the the final determination, and then we monitor them and evaluate that at the end of the year. So Okay.

And I think we would certainly, so, I mean, to to that group such that they are listening, please take a look at business plan three and the end of year determinations. Are they public?

Are they Yes.

Our final determination is, public. We published that, oh, was it April or May this year? So that's for the business plan period we're in at the moment, which is this financial year. And then we will be monitoring performance over the course of the year.

And then at the end of the financial year, we do a formal assessment of their performance, then we publish that. And that as well kind of that there are those reputational incentives, but NESO's, performance is also tied to their kind of executive remuneration as well. So it's a public organisation now, NESO, so we don't have financial incentives like we used to set for the ESO, but we have a very public evaluative assessment which links to NESO senior staff remunerations. There are still lots of checks and balances in that process.

Okay. And maybe, really interesting, to get into a little bit of the detail, around kind of the process of putting a number in place. I I think the number is really important. Like, parity should be objective enough, but I think could be quite subjective. So just in terms of putting numbers to this and and the process of kind of setting that up, how how do Aeso go about doing this? Because it is a complicated topic.

Yes. It is it is complicated, and that's why we've said you need to work closely with the industry to agree the metric because I think they had a metric and there were some comments from industry about, oh, that's not quite working as desired. So we've required them. They engage and and I go to these meetings as well.

There's a battery coalition, meeting that they have. So we are seeing we're monitoring very closely. They're doing a lot of engagement, with industry on that. So I think they've got a team now dedicated to this issue as well.

So I think the momentum is there. I think we just need to keep working closely with them and the rest of the sector to make sure that that's sort of seen through to the development of an actual metric and some numerical targets against that.

So with with topics like, topics that are really nuanced and specific to industries, this must have come up in other sectors. Right? So Yeah. The kind of the the the trap here feels a little bit like you get a group to, assess their own work Yeah. A little bit sort of like marking your own homework here. So as a regulator, how do you kind of in such a complicated topic such as dispatch from a national control room, how can you actually get them and get there to be a balanced review of that process?

First of all, it's about the metric, and you want a metric that you can be confident in. And I think that's why you need to work, with partners with the industry to develop a metric that everyone's happy with. Because I think I have seen, in the past sort of metrics that are developed and actually you realize there's sort of lots of wheezes and ways to kind of get round sort of the metric, and it's not really achieving what you want it to do. So I think at the outset, you want a metric that everyone is comfortable with, is robust.

I think you need a bit of data as well so you can understand how that metric sort of evolves over time.

Then I think you need transparency in terms of, here's the agreed metric, and I'm gonna publish the data so you can actually see the metric. You can see the performance against it, and it plays out in the public domain. We have an independent regulator. So I think that does get around the issue of kind of marking your own homework because you take people with you on the method, and then you're kind of pub you're transparent about your performance against that method and against those standards. So I think I think that's sort of how you get comfortable with this is not someone marking their own homework.

And and, actually, I really like that answer in that it's not you're not saying he's kind of gonna be really definitive. Mhmm. Actually, things like skip rates are a bit opaque, and there is room for an element of kind of if as long as both sides are talking, both sides agree. So industry and and and NISO, there's there's an agreement in terms of how the assessment might change.

As long like, I I I would definitely say there's probably some need for flexibility from both sides. Maybe marking the homework so far, I'd say we're maybe halfway there on skip rates. We'll we'll see. May maybe, maybe, maybe both sides would be upset with that.

Who knows? So that's that's my assessment.

And it's a challenging issue, is it? This is not easy stuff kind of. It is challenging, but you're right. We do need to see substantial improvements quickly on this issue because we recognize it's an issue that's very important, not only for kinda consumer costs in the short term, sort of picking sort of actions that are outside of that merit order sort of increases costs for consumers. But you mentioned also that sort of that knock on effect of then it impacts uncertainty and investment and things like that. So you're right. It's an important issue that we need to get on top of very quickly.

And and just to give people a sense of the size of the datasets, we look at it monthly, but we all when when we do sort of deep dive into that particular dataset, it can be, you know, weeks, multiple weeks of actually looking through to understand really what's been going on because it is quite nuanced and there is a lot of data in it. So Yeah. Yeah, a very a very, in-depth topic. Yes.

Okay. So, looking now to move us on to the final two questions. Yeah. And so first of all, is there anything you'd like to plug?

Well, I think I've been plugging the cost allocation and recovery review, this whole episode almost. So, yeah, we published a call for input on that at the end of July. We really are wanting a wide range of responses. We've tried to make that call for input as accessible as we possibly could, and so we'd really like to hear from as wide a range of stakeholders as possible.

It's from consumers to energy economists Yes. To utilities.

All views. Yes. Yeah. The views about closing date is the twenty fourth of September, but we would really welcome views on that. So, hopefully, this podcast goes out in time.

This podcast will go out in time. We have a a guarantee of of of that date. And then my final question is, are there any contrarian views you hold? So is there something that you believe that the majority of the market doesn't?

Yes. Yeah. I'm not sure if this is energy specific, but as a regulatory economist, I have quite often found found myself advocating for sort of simplicity, and some people might call that crudeness, and we need sophisticated, complex regulation. But I think there are some real benefits to simplicity.

And sometimes, we need to think about can people actually respond to some of those incentives we're we're setting. So, for example, I look at our network charging methodologies, and they're incredibly complicated and have becoming more and more complicated over time. And I think, my contrarian view would be, can we make things more simple?

Yeah. But I there's always a balance.

There's always a balance.

I I I really like that. And it's not only for consumers. Right? We have this problem all the way through battery customers from customer level, but also way eleven eleven kV, thirty three kV, one three two kV, all have different ways of charging for the network costs. Yes. And it it can be a bit of a maze at times.

Yes.

There was a very good episode we did from the Australian team that said, that talks around the energy industry's desire to try and get people to understand VPPs and virtual power plants. And they said, look, enough's enough. Stop trying to get people to understand VPPs. Nobody's as nerdy as we are.

Just Yeah. Just just allow them to save money and be happy with it. Yeah. And so I kind of think that actually is a really nice, a nice place to leave it.

Yeah. Georgina, thank you very much for coming on Transmission. We look forward to working our way through VP3 and the results of it in due course.

Great. Thanks for having me. It's a privilege. Thank you.