Citizens Advice response to ENA consultation on Application Interactivity and Connection Queue Management
Citizens Advice welcomes the opportunity to respond to this consultation as part of its statutory role to represent domestic and small business energy consumers in Great Britain (GB).
The Energy Networks Association (ENA) Application Interactivity and Connection Queue Management consultation presents an opportunity for the electricity transmission and distribution networks to standardise how connection applications are managed. A consistent approach across GB will be beneficial to the industry by offering a single clear process for developers, generators, and flexibility providers at both the application stage and during the ongoing development stage until projects are completed. Consumers will also benefit. This proposal should facilitate the growth of the flexibility market, help to decarbonise the energy sector, and reduce network costs for consumers.
The changes proposed to the Application Interactivity pre-acceptance stage for connections are based upon an existing UK Power Networks process and therefore there is a relatively high degree of confidence that these procedures will work as expected. We support the proposed modified ‘conditional’ interactivity process which should provide a clear procedure for allocating capacity while leaving initially unsuccessful applicants within the queue.
Proposed amendments to the Queue Management stage of the process builds upon previous queue management procedures and therefore, in principle, should be familiar to connections’ parties. The newer elements, comprising a standardised approach, along with clarified fixed milestones, and a tolerance to permit projects to get ‘back on track’, appear to be valid and useful amendments, which we support. The further additional change to add prioritisation to projects which offer flexibility, where there is the opportunity to postpone or avoid network reinforcement, is welcomed as this will reduce overall costs to consumers, speed the addition of flexibility to the system, and fits with the aims of the BEIS and Ofgem Smart Systems and Flexibility Plan 2017 (Action 1.6).
While the proposed changes are supported, we note that these standardised procedures may take some time to implement due to required code and licence modifications. We would urge the network companies to progress these changes as rapidly as possible to further facilitate the growth of the flexibility market, assist in the decarbonisation agenda, and reduce network costs for consumers.