Project TransmiT – CMP213 Working Group

HIE and Scottish Renewables have pooled resources to support the cost of a technical expert on the Project TransmiT (CMP213) Working Group responsible for developing transmission charging options. History has shown that interests in different parts of the UK have quite different agendas, and presenting a co-ordinated message is critical. With that in mind, a Team Scotland approach is being pursued. With cost reflectivity being of paramount importance to the Regulator, real solutions are being identified to offer potential for meaningful reductions in charges. The representative produces regular blogs which will be reproduced here:

Tuesday, 22 January 2013

Meetings 19 and 20, 17 and 18 January 2013

It was all about the consultation responses for the first two days back.  Whilst London turned white and Leicester was rocked by an earthquake, the CMP 213 Working Group was rather underwhelmed by the number of consultation responses: twenty one, most of them from Working Group members.  A consultation over Christmas probably didn’t help, and it is possibly a measure of how much else is going on in the industry right now.  

It made the review of responses manageble though, with most respondees confirming that the Group had probably widened out the scope of the Mod enough, with most asking for more development of, and outcomes analysed, for the multiple options on the table.  There were a few more wide-ranging comments, one complaining that the Mod’s purpose was to reduce charges for renewables and a few others saying it hadn’t done enough for the low carbon agenda.

There were no formal Consultation Alternative Requests – this basically involves filling in a form alongside your consultation response and detailing an Alternative which the Working Group then has to consider (but only adopt if it agrees its good).  One Working Group member had actually worked up some proposals which were nearly an Alternative.  This was on the back of some commissioned consultants’ reports, here – looking at the relative impacts of the sharing part of the proposal – and another report (link provided when available), critiquing the dual system background approach.  

Some respondees had asked for information on tariff impacts and a second chance to provide feedback on near-final proposals.  The Group’s existing timetable – approved by the CUSC Panel – envisages a final report to the CUSC Panel in March, which is already tight.  This then allows for a Code Administrator consultation, a CUSC Panel vote and an Ofgem impact assessment, with a decision in time for draft tariffs to be published in the autumn of 2013, for implementation in April 2014.  There may be a month or so flex if the CUSC Panel is amenable but not much more than that.     

We went down a governance alley talking about the relative merits of Consultation Alternative Requests and Working Group Alternatives, and what would happen if the Working Group held a second consultation.  CUSC-wise, it appears that Consultation Alternative Requests can only be raised alongside the formal, and once-only Working Group consultation.  But the CUSC Panel can agree to a second consultation, issues can be raised through this, and the Working Group can raise Alternatives at any time in its deliberations.  So in practice it is up to the Working Group to decide if issues raised at any time merit an Alternative, with the Consultation Alternative Requests formalising this in a form and a deliberately scheduled time period.

Notwithstanding the flexibility available to the group (and more so the Chair), in the interests of focusing on what’s on the table, we agreed to draw a line under any new Alternatives by the end of the next set of meetings (28th and 29th January) .  This isn’t a hard line, but it would probably have to be brilliant and / or quick-to-codify if it came after then.  [any ideas now or later, let me know]

We didn’t really land on whether to have a second consultation, but noted that there will be a Code Administrator consultation (this is for parties to raise practical issues with any of the proposals e.g. business impacts and costs of implementation), and that Working Group members are in touch with various stakeholders on an ongoing basis.  One of the main comments raised was about direction of travel for the Diversity options, with National Grid noting they had run some numbers on relative MWkm for the different options.  [if anyone wants these, let me know]

On analysis and production of tariffs, we had the discussion about whether the industry at large would take the numbers out of their work-in-progress context. There were mixed views [mine is limited information is fuel for misuse of what information there is, so would support releasing it appropriately caveated].  However the main issue is time.  We agreed that the Working Group will need to sense test some of the proposals against some draft tariffs (but not a full blown impact assessment), and the Working Group members will be able to explain this to their constituents.  

Otherwise it was a question-by-question run through of the consultation responses, some bringing up more issues than others.  In summary, islands and HVDC expansion factors had a pretty broad range of responses from supporting all the costs being charged locationally to some to none, with some debate about how HVDC compares to AC in terms of cost and function; sharing again had a very broad range of views and requests for more analysis; but in terms of options mostly it was all variations on what’s already on the table, pending what comes up in the next two meetings.

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