Distributed Generation Customer Experience Workshop€¦ · 09/09/2014 · Ilketshall Grid 22 15 7...

Distributed Generation Customer Experience Workshop 9 September 2014

Welcome and Introductions Steve Halsey Distributed Generation Development Manager

2011. UK Power Networks. All rights reserved

Safety and Housekeeping

• Toilets - Gentleman and disabled to the right, Ladies to the left

• Mobile phones

• No planned fire alarms

• Emergency exits

• Fire assembly point

• Please inform Kellie or Connie if you need to leave early

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Emergency exits Smile 1, 2, 3 & 4, Ground Floor, Prospero House

There are no planned fire drills today. If the fire alarm is heard please leave the building using the nearest fire exit. Once outside turn left onto Avon Place and assemble on Swan Street.

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Introductions Who’s here today?

Connections Mark Adolphus Director of Connections Iain Dilley Key Account Manager Connie Dickie Connections Communications Major Connections Steve Bradley Head of Major Connections Steve Halsey DG Development Manager Jim Vasey Major Connections Manager EPN Steve Foster Major Connections Manager LPN Steve Carlow Major Connections Manager SPN Steve Rogers CiC Manager Kellie Payne DG Business Analyst Kelly Dunston Project Manager Projects James Devriendt Connections Manager SPN Andy Braund Connections Manager EPN

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Asset Management Robert Kemp Head of System Development Allan Boardman Network Design Standards Manager Tim Moore Infrastructure Planning Engineer David Boyer Project Lead Smart Network Plan Neassa Mccabe Distribution Planning Engineer José Barros Infrastructure Planning Engineer Capital Programme Ian Cameron Senior Project Manager Adam Flude Senior Project Manager Customer Services James Hubbard Senior Stakeholder Engagement Analyst

Engaging with Customers and Stakeholders


Time Subject Type/location Presenter 09.30 Introduction/setting the scene All/main room SH

09.45 Director overview All/main room MA

09.55 Delivery – Where are we? All/main room IC/AF

10.25 FPP – progress update – move to Flexible DG Connections

All/main room DB/JB/NM

10.55 Engineering Standards - external consultation All/main room AB

11.15 Tea & Coffee

11.30 G59/2 – G59/3 All/main room TM

11.45 Management of capacity – feedback/review Break-out session Various

13.15 Lunch

14.00 Life after ROCs Break-out session Various

14.45 Q&A All/main room SB

15.30 Close

Agenda


Start doing/More of

Stop doing/Less of

Your feedback throughout the day

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Name:

Name:

We will review your ideas and opinions and will provide feedback to you at the next DG CEW 26 February 2015 as - You said/We did/We will do


DG Mapping tool enhancements

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CONFIDENTIAL

CONFIDENTIAL

CONFIDENTIAL


The Voice of the Networks

9

Mark Adolphus Director of Connections


Setting the Scene Our objectives for today

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To continue our engagement with you

To review our published 2014 Service Improvement Plan

To give you an opportunity to provide feedback to us


Where are we? Your views on seven key areas…

• Record scores on the score-sheet • Hand-in before lunch

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Where are we?Topic area 1 2 3 4 5 6 7 8 9 10

1 Our Information Provision2 The Application Process3 Our approach to Charging4 The Choice you have 5 Technical 6 Our Engagement with you7 Overall level of Customer Service

For each topic area above please put a cross in the box below the number that best represents

Name Company

Lowest --------------------------------------------- Highest

where we are today

0123456789

10Information provision

Application process

Approach to charging

Choice you haveTechnical

Engagement

Customer Service

Customer Feedback

27-Feb-14

22-May-14


DG Enquiries

13

Volu

mes

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

2008 2009 2010 2011 2012 2013 2014 actual&projected

Total

Projected

Actual


DG – 2008 to 2013 & Jan-Aug 2014 Enquiries/Quoted/Accepted

14

Volu

mes

0

1000

2000

3000

4000

5000

6000

7000

8000

2008 2009 2010 2011 2012 2013

Enquiries

Quoted

Accepted

1. S16 & SLC15 applications 2. Formal & Budget applications 3. Schemes cancelled pre-quote stage 4. Type tested <50kW


DG Customer Satisfaction score 2014

15

0

1

2

3

4

5

6

7

8

9

10

Jan-14 Feb-14 Mar-14 Apr-14 May-14 Jun-14 Jul-14

141 respondents

Average score 8.47

Delivery - Where are we? Ian Cameron & Adam Flude

2011. UK Power Networks. All rights reserved 17



What’s connected, to connect?

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EPN Connections

Jan - Jul 2014 Planned for

remainder of 2014

Planned for connection in Q1

2015

Planned for connection thereafter

TOTAL Number of Connections 75 27 43 36

TOTAL Capacity of Connections in MW 357 312.5 820 795

SPN Connections

Jan - Jul 2014 Planned for

remainder of 2014

Planned for connection in Q1

2015

Planned for connection thereafter

TOTAL Number of Connections 15 30 21 6

TOTAL Capacity of Connections in MW 68 351.7 275.84 122.10


Looking Ahead

• UK Power Networks have trialled the POC mast solution, enabling access to 33kV Steel towers. This solution is now undergoing further evaluation to see if it can be considered on a wider scale potentially offering savings over conventional methods, also reducing time and technical risk to connect to the network prior to financial deadlines.

• Operational intertripping solutions are in the final trial period, thus for specific circumstances where an operational intertrip is required, UK Power Networks will be able to facilitate most requirements via our existing protection / telecommunications networks, thus reducing the cost of cables back to the tripping breaker, this solution reduces cost and further mitigates connection risk.

• Through working closely with developers and understanding the constraints/criteria required before full financial commitment is able to be made, UK Power Networks have outlined an “Off – the-shelf” Modular package substation for 33kV generation connections based on our own spatial, environmental, security and quality requirements with the aim of minimising the design assurance timescales required. 3 sites are to be selected to trial this solution prior to issuing into the market to place orders.


Responding to the challenges

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• Increased generation ABSD stock levels are now held for emergency situations.

• Following from a lessons learnt session post March 2014, UK Power Networks have compiled a G59 training plan for existing internal commissioning resource, this cross pollination of resource allows UK Power Networks to be more flexible in witness testing/G59 testing within the annual March rush.

• UK Power Networks have increased critical resource by 58% to accommodate the heightened workloads pre-March each year, to further ensure UK Power Networks continue to support all developers in achieving 100% of all in build projects prior to deadlines.

Our Journey - FPP to Flexible DG Connections David Boyer, Neassa McCabe, José Barros




The Flexible DG Connections project is expected to develop a consistent business-wide approach to offering flexible DG connections based on the work that is being undertaken by innovation projects and existing solutions the business is using. A Flexible DG Connection is where the output of the generator is curtailed or constrained in specific instances to maintain the network within its operating limits, relying on:

A technical solution, with the means of communicating with and controlling generators in order to deliver the required flexibility/curtailment Commercial and contractual rules, that determine priority of access to the constrained network capacity across a range of customer and network sites

Flexible DG Connections: rollout project

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Flexible DG Connections: Objective & Benefits

The project will consolidate best practice for the technical and commercial designs of non-standard connections, and will introduce a flexible connections tool kit available to all relevant users Customer benefits*:

• Cost-effective method for providing connections in constrained parts of the network

• Reduced construction timescales when compared to BaU • Customer choice

RIIO-ED1 Business Plan Commitments:

• Integrate Flexible Plug and Play connection offers into BaU by Q2, 2015 (as per our Low Carbon Network Fund Project)

• Important new activity in the area of customer services

*Depending on level and complexity of constraints

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Steve Halsey DG Development Manager

José Barros Infrastructure Planning Engineer

David Boyer Smart Network Plan Lead

Graham Ault Development Director - SGS

Neassa McCabe Distribution Planning Engineer

Sotiris Georgiopoulos Project Lead

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The project team


Flexible DG Connection Solution Roll-out Roadmap • Identified network geographies, voltage levels and specific constraint (of defined types)

mapped to BAU Flexible DG Connection Solutions

Network Data • GSP + Grid Substation + Primary

Substation data sets / models • Planner constraint pre-filtering notes

(underpin heat maps)

Generation Development Data

• Generation connection application volume (ORED

database) • Connection quotations

Candidate BAU Flexible DG Connection

Solutions • Mapped to identified pre-

defined constraint types • Understand diversity

Application of Screening Criteria • Definition of Generation Indices • Transmission constraints at GSP • £/MW quoted connection costs

• Solution complexity (e.g. interacting constraints, multiple voltage levels) • £/MW-enabled Flexible Solution cost

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Approach to rollout design


Example data assessment

• Application of screening criteria to grid substations in the Norwich GSP group shows: – Clustering effect – High number of 132kV offers – Other indicators: Unit cost per connection, remaining grid capacity, description and

number of constraints per grid site • Considering application of GSP where Statement of Works is required to determine

allowable reverse power to NG – network constrained top-down in many areas

Grid Substation Name Received DG Connection

Requests Accepted Connection Offers Closed Connection Offers % of Closures at LV

% of Closures at 11kV



MVA number number percentage percentage percentage percentage

Earlham 132 5 0 5 0% 0% 40% 60%Earlham Grid 202 60 142 0% 6% 66% 28%

Gorleston Grid 2 2 0 0% 0% 0% 0%Gt Yarmouth Grid 21 7 14 0% 21% 79% 0%

Ilketshall Grid 22 15 7 0% 29% 43% 29%Lowestoft Grid 11 4 7 0% 14% 86% 0%

Norwich Main 132 2 2 0 0% 0% 0% 0%Sall Grid 55 28 27 0% 37% 63% 0%

Thorpe Grid 8 4 4 0% 0% 100% 0%Trowse Grid 15 10 5 20% 40% 20% 20%

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Strategy: Network constraints considered

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Constraints in scope: Thermal, Reverse Power Flow, Voltage


Solution Description Cost Limitations

Diversity driven Diversity due to generation mix / loading conditions Operation of non-solar DG outside solar windows

Low cost Generation mix, volume of DG connected

Operational Inter-tripping

Inter-tripping based on non-hardwired communications

Low – Medium Cost

Curtailment may be disproportionate to the constraint

ANM Dynamic turndown of DG Medium – High cost

Level and volume of constraints

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Strategy: Possible solution types


Curtailment Assumptions

⃝ Network Configuration

⃝ Demand Growth

⃝ Micro-generation growth

⃝ Capacity factor for generation connected

⃝ Number of constraints

⃝ Generation mix

⃝ Principles of access

Flexible Plug and Play Briefing

Document ANM

CONNECTION AGREEMENT

Terms & Conditions

Connection Offer

£

Design – curtailment assessments

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Customer feedback highlights the importance of: • Strong commercial arrangements

• Minimising uncertainty to projects

• Transparency

• Access to data and assumptions

• Potential independent assessment

• Cross-validation to give confidence to

investors/financiers

• Up to 5% yearly curtailment seen as acceptable for solar/wind (up to 10%/15% for dispatchable)


Design: Commercial strategies

LIFO PRO-RATA PRO’s • More Simplicity

• Widely applicable to different constraints and locations

• Shared risk of curtailment • More effective in connecting DG • Relevant to specific type of constraints • Worst-case curtailment can be identified

CON’s • Last generator takes curtailment risk

• The curtailment rates will increase more quickly

• Less players are likely to connect when compared to Pro-Rata

• Can penalise some generator types • Complex in design & operation • Curtailments still dependent on other

generators in the scheme

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G

G G

G G G

Reinforce transformer

Reinforcement

L

Customer feedback:

• Support & concerns for both LIFO & Pro-rata

• Support for reinforcement terms included in agreement – if clear upfront • Need for clarity & consistency across industry on planning permission

requirements, etc. • Understanding of the need for assessment fees on the grounds of additional

studies being required


• Analysis on level of network constraints, solutions and commercial strategies will inform business roll out strategy

• Detailed technical standards and commercial policies to follow • Develop specifications and procure necessary equipment and services • Implement the necessary training, changes in skills, systems and processes

• Clarity of offering strategy will be provided early 2015 • Flexible offers will be available by the end of Q2, 2015

• UK Power Networks will not make Flexible DG connection offers ahead of

completion of this project, in order to prevent ad-hoc, conflicting, or inconsistent schemes to be introduced

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Next steps and timeline

Engineering Standards – External Consultation Allan Boardman




An introduction to Engineering Standards

• Overview of Engineering Standards

• The Engagement / Consultation Process »Design Standards Communication – to date »Trial of external engagement process »Design Standards Communication – future

• Forthcoming standards being reviewed »2014 review programme


• Circa 600 standards & procedures • Circa 400 associated drawings • The network is evolving with the advent of smart

technologies – the standards will require review and updating

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Director of Asset

Management

Head of Engineering Standards

Network Design Standards Manager

Substation Standards Manager

Circuit Standards Manager

Civil Standards Manager

Compliance Manager

Smart Network Plan

Manager

Overview of Engineering Standards

The Engagement / Consultation Process


Design Standards Communication – to date

• Publication of technical standards via our ‘G81’ website »Circa 500 engineering standards, specifications and drawings »Positive feedback received

• Improved internal process for review of standards » Increased awareness »Standards developed using field/customer experience

• Trial to extend internal review process externally

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Minor Amendment (Typo, restructure, no content change)

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Design Standards Communication

Internal Process (Triggers,

major/minor, review)

Major Amendment (Impact Internal/External)

Final Draft Produced

Collate views and discuss at

internal review forum

Update document

accordingly

Provide feedback on comments

received

Create comms/ implementation

plan

Notify stakeholders,

load onto library, implement

change

Review and amend document


plan



change

Approval

Approval

Discuss at forums (where

appropriate)


Approval of Plant

Notify requestor and close (record on G81 website)

Go to review standards

process

ENA approved?

Gather technical information;

Agree requestor to fund all

reasonable costs

Negotiate with supplier including factory/witness

test

Agree with requestor costs or

strategic spares

Letter of acceptanc

e received?

Required change to standards?

Communication plan and update G81

website

External request for

non-approved plant

No

No

No

Yes

Yes


Minor Amendment (Typo, restructure, no content change)

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External Engagement - Trial

Internal Process (Triggers,

major/minor, review)

Major Amendment (Impact Internal/External)

Final Draft Produced

E-mail trial group for comment

Collate views and discuss at

internal review forum

Update document

accordingly

Provide feedback on comments

received


plan



change

Review and amend document


plan



change

Approval

Approval

Discuss at forums (where

appropriate)

• Trial group of 40 including developers and ICPs • Draft Standard sent via e-mail with comments form • Eight replies received and document revised


Design Standards Communication - future

• Extension of the external communication trial »Using G81 website – “Documents for Comment” section

• Enhancement of the G81 website »User logon to personalise interface »Subscription to documents – automatic updates »Discussion forums

• Further development of review standards process as part of UK Power Networks Business Transformation Programme

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Future Standards / Reviews


2014 Review Programme

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Document No

Document Title Comments Relevant to DG

EDS 06-0014 Secondary Substation Earthing Design Complete – Published YES

EDS 06-0017 Customer Installation Earthing Design Review against G12/4

ECS 06-0023 Secondary Distribution Network Earthing Construction Standard

Complete – Published YES

EDS 08-0030 LV supplies to mobile phone base stations mounted on towers

Complete – Published

EDS 08-0113 Guidance for ENA ER G88 and G81 Inset Networks Review due 2014

EDS 08-0123 LV Electrical Service Drawings Complete – Published

EDS 08-0129 Underground Services up to 100A Single Phase Review due 2014

EDS 08-0133 Underground Services to Unmetered Street Furniture Review due 2014

EDS 08-0136 LV Network Design Standard Review due 2014

EDS 08-0141 Customer HV Supplies Complete – Awaiting final approval YES

EDS 08-0149 Customer System Interface Complete – Awaiting final approval YES

EDS 08-0150 London 33kV Distribution Network Design and Customer Supplies

Complete - Published YES

Break Please reconvene at 11:30am

G59/2 – G59/3 Tim Moore




G59/2 – G59/3

• A wide range of industry stakeholder’s were on the working group

• Public consultation during March – May 2013 • Engineering Recommendation (EREC) G59/3 was

published in August 2013, with an implementation date of 1st September 2013

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G59/2 – G59/3

• Distribution Code Requirements • All Users of the Distribution system have to comply with

the D Code

• DPC7.2.1 Embedded Generators connected to the DNO’s Distribution System will comply with the requirements of Item 3, DGD Annex 1 Engineering Recommendation G59/3-1, “Recommendation for the connection of generating plant to the distribution systems of licensed distribution network operators”

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G59/2 – G59/3

• Distribution Code Guidance Note 2/4 issued Sept 2013

• Connection of small scale embedded generation of above 16A per phase made before 1st December 2014 can be in accordance with either G59/2-1 or G59/3-1. Such connections made after 1st December 2014 must be made in accordance with G59/3-1

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G59/2 – G59/3

Therefore to connect under G59/2-1 you must be;

• LV connected • Have type tested equipment certified in accordance with

G59/2-1 • Generating units must be 50 kW or less, 3 phase

All other generation must now connect under G59/3-1 After 1st December all generation must connect under G59/3-1

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G59/2 – G59/3

• What are main differences between G59/2-1 and G59/3?

• Changes were mainly at LV • Better defines requirements for type tested equipment • Settings aligned with G83/2

• At HV settings are essentially the same • Testing requirements re stability. Some test sets not

capable of confirming compliance • Requirements that phase/site is complete prior to test

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G59/3 – G59/3-1

• G59/3 has now been updated to EREC G59/3-1 in August 2014

• What are main differences between G59/3 and G59/3-1?

• ROCOF settings Changed • Applies for all new and existing generation > 5 MW • All existing sites will need to have revised settings

applied by August 2016

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G59/3 – G59/3-1

Ω The minimum setting is 0.5Hz/s. For overall system security reasons, settings closer to 1.0Hz/s are desirable, subject to the capability of the generating plant to work to higher settings.

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Management of Capacity - The Consultation Steve Halsey




Management of Capacity

• Issued 8th August • Questions & Minded To position • 26 responses

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• Key area for stakeholders • Capacity highly utilised • Important that we seek views

• Valueable responses • How do we integrate into BaU • What next?

Management of Capacity – feedback/review Steve Carlow, Steve Foster, Jim Vasey


Interactivity and queue position

Interactivity and Queue Position Q6.4.1

Are our communications (for example our Notices of Interactivity, Interactive

Connection Offers, discussions with UK Power Networks contact) clear about the

implications of interactivity? How could these be improved?

Q6.4.2

Do you believe that our current reduced validity period of 30 days for Interactive

Offers is fair? If no, what do you believe is a fair validity period?

Q6.4.3

Do you think that being provided the queue position at the point of Conditional

Connection Offer is valuable? What other information would you like at this stage?

Q6.4.4

Do you have any comments or feedback on our Minded To position for Interactivity

and Queue Position?

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Material changes

60

Material Changes Q7.4.1 Do you believe our approach to Material Change is fair and reasonable? What

should we or should we not consider to be a Material Change?

Q7.4.2 Do you believe our approach to ‘Splitting of Accepted Schemes’ to be fair and

reasonable? Do you have any alternative suggestions?

Q7.4.3 Do you believe we should acknowledge the unique requirements of Community

Energy schemes? What if anything should we do differently?

Q7.4.4 Do you believe our approach to the change of technology type is fair and

reasonable? Do you agree/disagree that this should be considered as a Material

Change?

Q7.4.5 Do you agree/disagree with our approach to Requested Export vs Available

Capacity? Do you have any alternative suggestions?

Q7.4.6 Do you have any comments or feedback on our Minded To position for Material

Changes?


Releasing capacity

61

Releasing Capacity

Q8.4.1 At which stage should released capacity feed back into the network (Stage A to

E)?

Q8.4.2 Do you have any comments or feedback on our Minded To position for Releasing

Capacity?


Interactivity and Queue Position

MT6.3.1 UK Power Networks will continue to base all Interactive Queue positions on the Application Date, as we believe

this to be the most fair and equitable approach. It maintains the guiding principle of ‘first come first served’ and

sets a clear unambiguous reference point when reviewing Queue positions as they change over time.

MT6.3.2 UK Power Networks will provide an indicative Queue position when a Conditional Connection Offer is issued i.e.

for subsequent Connection Offers when in an interactive queue.

MT6.3.3 An Applicant’s queue position may change over time following a Connection Offer. UK Power Networks will

provide an Applicant’s current queue position upon request.

Interactivity and queue position


Material Changes MT7.3.1 UK Power Networks will continue to apply its current policy with regards to the criteria that constitutes a Material

Change to the Application. All other changes to the application are subject to a review to confirm if they are to be

regarded as a Material Change or not. MT7.3.2 UK Power Networks will continue to take the following action where any updates/amendments are considered

Material Changes:

i ) re-set the Application Date at the Quotation Stage, or

ii) withdraw an Accepted Scheme with the subsequent release of the scheme’s committed capacity. MT7.3.3 Where we are aware of the “Splitting of Accepted Offers” into multiples of less than 5MVA we will consider these in

line with the following example:

If we receive a request to split 10MVA into two 5MVA schemes the first portion of 5MVA will be allowable i.e. this

can be considered as a reduction of export requirement from 10MVA down to 5MVA. We would not regard this as a

Material Change and is therefore allowable under our current policy.

If the Applicant wishes to connect the remaining 5MVA to a second Metering Point this would normally require a

second substation to be established. We would consider this to be a Material Change because this would normally

prompt a re-design of the solution and re-analysis of the application requirements.

We are awaiting DECC’s finalised position of their Consultation Document of 13 May (Consultation on changes to

financial support to solar PV) where they have specifically stated that they will monitor closely deployments of

5MVA and below.

Material changes


MT7.3.4 We do not consider the change of technology type as a Material Change, therefore we will consider these requests

on a case by case basis. However there will need to be a reassessment of the design and this will be subject to an

additional charge. Note that this reassessment may have an impact upon the size of the original export capacity

requested. MT7.3.5 We can consider the request for a Community Energy Scheme to be connected as part of a larger accepted DG

commercial development, however the Community Energy Scheme would need to complete a new application form

initially. An agreement would then need to be formulated between the Community Energy Scheme and the DG

Developer whereby the DG Developer would release the required export capacity to the Community Energy

Scheme. The Community Energy Scheme would need to satisfy the qualifying criteria as defined by DECC. MT7.3.6 For instances where there are no identified interactive applications we will enter into dialogue with the customer

regarding the available capacity on the network, such that the export requirement can be amended under the

Material Change process without any risk to queue position.

If there is an identified queue then we would need to process the enquiry as per the original request.

Material Changes …….contd.

Material changes


Releasing Capacity MT8.3.1 UK Power Networks will release capacity in reverse order from Stage D (Pre Commencement of Works) in order of

application date.

MT8.3.2 UK Power Networks will not advertise where specific capacity has been released. UK Power Networks will

continue to provide information through its normal channels e.g. Long Term Development Statement, Heat Maps,

DG Surgeries or through the Application Process.

Releasing capacity


Typical Project timeline & key milestones

66


Q6.4.1 Are our communications (for example Notices, Interactive Connection Offers, discussions with UK Power Networks contact) clear about the implications of interactivity? How could these be improved?

67

1

There are two improvements which would significantly assist interactive applicants: 1. Provide an indicative queue position when Conditional Connection Offer is issued (as Minded To position) and update by email whenever queue position of that offer is changed. 2. Provide information on the participants in the queue so that a party with a Conditional Connection Offer can assess its likelihood of becoming unconditional. This would also enable queue reduction through allowing parties in the queue to come to bipartite agreements on whether to withdraw one application. There has been concern voiced over confidentiality issues but a process similar to this was used by National Grid in 2007 onward to manage its connections queue, identifying offers and connection dates by party, generation type, capacity and connection point. We are not aware of any confidentiality requirement that would prevent a DNO publishing application type, applicant name and capacity for each substation for all applications.

2

A general suggestion however would be to make the communication process more interactive perhaps via a web portal (similar to what most local council have for planning applications). This way customers could see for the progress of their application i.e. when it is accepted, when a quote is expected etc. I feel that this would very much save time and resource for UKPN i.e. customers calling in with status updates etc. I also feel that within this design process that work that UKPN undertake in order to arrive at their assumptions should be shared with the customer as this will again save UKPN resources (i.e. the customer questions why can’t we have a 33kv connection etc.

3 The interface is good at present. It seems that other DNO’s feel able to share more information regarding higher queued accepted offers in their LTDS (notably Northern Power Grid (NPG)) the level of information contained in NPG’s LTDS provides a better level of knowledge for developers to make commercial decisions and it seem to be of benefit of both UK PN and developers to share the same level of detail as contained in NPG’s LTDS Appendix 7.

Around 70% agreed in principle with UKPN’s Minded To Position


Q6.4.2 Do you understand the need for us to reduce validity period of Offers to, or Issue Connection Offers with, 30 days quotation validity?

1

I think it would help to separate the validity of the offer from the management of interactivity. The quotation itself may remain valid for a longer period, however I recognise the need to manage the interactivity in a shorter period. Interactivity is best managed with defined moratorium periods, which permit the first-comer a reasonable period to digest and respond, after this moratorium period elapses without signature then a second-comer may gain the preferable connection by signing first (this is what is achieved with the existing UKPN process, but I would argue the specific timings make acceptance very difficult). Any customer receiving an interactive offer should have plenty of warning as early as possible during the offer preparation period. Many developers will require board approval or similar to grant authority for signature, this process typically takes 2 months, so a lot of preparation must be done by the developer pre-offer-issue in order to facilitate signature within 30d. A central problem is UKPN’s policy to immediately cut existing offer validity to 30days on the receipt of an interactive application – this means that without any notice a developer must scrabble for board approval within 4 weeks which can be extremely difficult. As you are aware, other DNOs do not render the first offer interactive until the second offer is to be issued. This has two major advantages: 1) The first developer may be warned of the imminence of interactivity before the offer is cut to 30d validity. This allows preparation to be made for internal approval of the offer in the subsequent shorter validity period. 2) Discussions between 2nd developer and DNO during offer preparation period (and potential subsequent modifications therein) may mean that the second offer does not need to be issued, or is modified in some way which avoids interactivity. However you choose to solve this, fundamentally having the offer cut to 30d validity without any prior warning is a serious problem in facilitating offer acceptance.

2

Yes we do understand the need to reduce the validity period, and other DNOs follow a similar procedure. 30 days is actually a long interactivity period compared with that of other DNOs (usually between 1-2 weeks), although 30 days is usually more beneficial for cash flow purposes and allows our accounts department more time to budget for the expensive acceptance fee. If a smaller acceptance fee of £10,000-£15,000 could be agreed then a shorter interactivity period would be suitable. £50,000 is a large sum of money to pay on acceptance, especially for an interactive offer where securing the grid is not guaranteed. A smaller acceptance fee would be more reasonable is this instance



Q6.4.3 Do you think that being provided the queue position at the point of Conditional Connection Offer is valuable? What other information would you like at this stage?

1 It is essential. Also: how many other applicants in the queue, their capacity, their proposed connection dates and technology type – allows us to better understand the commercial risks associated with signature or alternatively consider a delayed re-application.

2

Yes, being provided with the position in the queue is really valuable as it often affects a customer’s decision as to whether to accept an offer or not. For example, if we were told we were 2nd or 3rd in the queue we would certainly consider accepting the offer, but if we happened to be 9th or 10th then we might not. At the offer stage I think we also need to be given a fixed date for which we will know the outcome of the interactivity. In a previous interactive case we accepted and paid for the offer on 16th May, but we did not know until 3rd July that we had won this offer. Furthermore, there needs to be clearer guidelines regarding refunds for any money paid on acceptance if we lose out on interactivity. It would be useful for the refunds procedure to be detailed in the offer as for many customers this may be a deciding factor as to whether they accept or not. For example, if the refunds procedure is lengthy customers may not want to part with such a large amount of money .Having said this, we completely understand the need to pay a fee on acceptance.

3 Yes. I also think UKPN could release a statement of available capacity at this point. I can’t see how it would breech any of UKPN’s statutory obligations, and it would assist all parties to make a judgement of their likely success which would in turn help them to prepare for accepting an offer or not. There is a lot of information publicly available through the planning system etc about what other projects are ongoing / potentially competing.

100% agreed in principle with UKPN’s Minded To Position


Q6.4.4 Do you have any comments or feedback on our Minded To position for Interactivity and Queue Position?

1 First is first. Fair enough. The issue is really how you keep people informed about changes to the queue. Do I need to keep resubmitting to keep in the queue?

3

We generally concur with the minded-to position. It remains appropriate for Interactive Queue positions to be queued based on Application Date. However, developers will have nothing to prompt them on whether to request a queue position update. Clearly providing formal notices for queue position is excessive, but an update of any changed queue position by email only would be very useful.


1

1. Increase in capacity. I understand the rationale, but overly strict interpretation drives applicants to over-estimate their capacity, hence artificially sterilising network capacity (noting there are no penalties for a capacity reduction, if performed in sufficient time or if design remains unchanged). There must be a level of increase which UKPN could interpret as immaterial, providing that the fundamental connection design remains unchanged (eg a change in thickness of cable is a small change, a change in voltage or PCC is a material change. By way of example, one popular turbine manufacturer market a turbine at 2MW, another markets at 2.05MW. Changing supplier from A to B would normally incur a 2.5% increase in capacity – such a change could be reasonably considered material. I am not asserting the value of 2.5% as anything other than an example – I would suggest UKPN consider a policy which permits increase in capacity of up to X% provided such increase does not cause a significant change in connection design nor trigger major upstream reinforcement. In a similar vein, where customers should be incentivised to be as realistic as possible with their connection applications, a very large drop in capacity should also be considered a Material Change. 2 CiC vs All-works Offers. This is not a material change. To interpret this is as such is a barrier to competition and artificially driving customers away from ICP options. It must be possible for a customer to initially choose an ICP option, then after reasonable consideration period to then appoint UKPN as their chosen connection provider, resulting in a change to an All-works offer – this must be possible without incurring interactivity penalties! In spirit of facilitating competition the reverse should also be possible (a move to ICP offer from all-works – providing the customer covers reasonable costs incurred by the DNO in relation to the all-works works which were aborted, and makes the change in a reasonable timeframe (pulling out of the UKPN all-works contract after UKPN had mobilised for construction would be clearly unfair). I note that other DNOs permit these CiC changes without resetting the customer’s interactivity position. Where there is a Material Change: Pre-Quote: to reset the clock on Offer preparation is reasonable, I agree.

Q 7.4.1 Do you believe our approach to Material Change is fair and reasonable? What should we or should we not consider to be a Material Change?

25% agreed in principle with UKPN’s Minded To Position


2

We disagree with your current policy regarding Material Change Post Offer Acceptance, in the instance of increased generation capacity. Also we do not agree with the policy of switching quotation types, i.e. switching between Section 16 and CiC being considered Material Change. We feel is should be possible to switch between these post offer acceptances. All offers should be “convertible “ with Section 16 and CIC options. Section 7.1 lists an increase in generating capacity as a Material Change, it does not list a decrease in capacity as a Material change. This contradicts section7.2 where a decrease in generation capacity is described as a Material change under current policy. We are strongly of the opinion that a decrease in generation capacity should not be a Material Change. We believe that a change in technology is not a material change, especially moving from wind to PV. Wind is far more onerous in terms of dynamic network effects therefore a chart of possible movements should be done.

Q7.4.1 Do you believe our approach to Material Change is fair and reasonable? What should we or should we not consider to be a Material Change?


Q7.4.2 Do you believe our approach to ‘Splitting of Accepted Schemes’ to be fair and reasonable? Do you have any alternative suggestions?

1

Need to be very wary of developers trying to ‘game’ the incentive mechanisms available. A good outcome would be if UKPN could make DECC aware of such applications, even there was any doubt about the application. Developers should not be artificially splitting a single scheme to achieve better tariffs, and UKPN should be cautious about delivering such ‘multiple’ connections regarding its license objective to facilitate competition in generation of electricity (as it potentially offers unfair advantages versus developers who base their applications on what is an appropriate MW output for the site).

2

I do not see where splitting of schemes has any impact on UKPN or its customers. The same MVA will be delivered to the new DG customer whether through 1 or 2 metering points and in fact will raise higher revenues over the life of the scheme through paying for an extra metering point. There will be an increase in contestable and non-contestable works although this is common place and allowable in all generation and load connections. I would suggest that provided kVA and fault levels are not breeched from the original connection offer, and no other/extra POC is required then a developer should be allowed to both split the capacity and request an extra metering breaker(s).



Q7.4.3 Do you believe we should acknowledge the unique requirements of Community Energy schemes? What if anything should we do differently?

1 Community Energy is a difficult subject. We appreciate DECC’s requirements and the need for it but it should be treated as any customer would and not take precedence; this could be a conflict for a DNO licence. In the future a lot of development projects will include a community benefit. DNOs need to provide clear guidance if doing anything differently.

2 Where the community Scheme is just that, solely a Community Scheme then UKPN should endeavour to help with their processes as much as is possible. Where a Community Scheme is being tacked on to an existing or large commercial scheme, for whatever reason, then it should be subject to the standard commercial treatment.

3 Will UKPN facilitate between the CES and the Developer? How will either of the parties know that they are trying to connect on the same area?

Views split roughly - 1/3rd for , 1/3rd against & 1/3rd undecided


Q7.4.4 Do you believe our approach to the change of technology type is fair and reasonable? Do you agree/disagree that this should be considered as a Material Change?

1

A fundamental change in technology (e.g. the power source – from say solar to biomass) IS a Material Change. A change in choice of electrical generator (insofar as UKPN’s connection design isn’t materially affected) is NOT a Material change (e.g. a wind farm changing it choice of turbine supplier resulting in a change of generator technology) – as stated subject to UKPN’s consideration of the design impact. Clearly, a change in generator which changes e.g. fault level contribution or e.g. ability to manage reactive power, and does so to the extent that UKPN must materially change the design, well that is Material.

Views split roughly - 1/3rd for , 1/3rd against & 1/3rd undecided


Q7.4.5 Do you agree/disagree with our approach to Requested Export vs Available Capacity? Do you have any alternative suggestions?

1 We disagree with your approach on requested export vs available capacity, if an application for 10MW is submitted you should instruct the developer that only 9MW is available and allow them to reduce their application without restarting the clock, this will stop developers having to apply for sites numerous times to find the MW that is viable.



Q7.4.6 Do you have any comments or feedback on our Minded To Position for Material Changes?

1

I do not agree with the splitting of capacity as I do not see how it has a material change on UKPN or their customers. Metering points would still have to be on the same landowners property. I also believe that an infrastructure only offer should exist whereby a developer can apply for capacity to split projects at their behest subject to meeting timeframes for delivery so as not to sterilise the capacity. This small power splitting is material compared to sterilisation by new major power stations, the investment required for this level of DG should not be treated any differently, the need to slow down the solar industry or make sure it is in the correct place is already dealt with by DECC through the RO/ROOFIT and the planning system.


Q8.4.1 At which stage should released capacity feed back into the network (position A to E)?

1

If capacity is to be released later than position B, all parties should be made aware of the existence of newly released capacity at the same time. Opening it up to a later stage than B raises the question about who should be prioritised… why should application date be the deciding factor? For example, should a project that already has planning consent and has committed financially to the connection of the project not get priority over the project that still sits in the planning process?

2 Capacity should be offered back to a Customer right up to Stage E as whilst works may well have started the savings offered by the new capacity may far outweigh the monies spent on the works completed to date.

3

I think a key issue for UKPN is “releasing the reserved capacity and then ensure that the same situation does not occur again. A couple of fundamental points on this; #1 There are people who have reserved capacity but not progressed their project #2 A clear and quick policy needs to be put in place to remove these “grid squatters”. I feel the proposal to weed these out over a 12 – 15 month period is not acceptable. I would propose that UKPN write to all of these customers demanding a second stage payment and stating that the initial deposit will be spent on design works will happen and that the customer has 30 days to reply or their offer will be cancelled is the correct approach #3 To stop the same thing happening again I believe connection offers should have key milestones i.e. first payment, within 3 months a second payment an notice that first payment will be used for design (i.e. customer is at cost), 6 months update on if planning has been submitted and then if after an additional 6 months planning has not been granted / appealed then the capacity is released automatically #4 I believe UKPN should charge for its resource i.e. initial design charges, application fees and these should be in the order of £5,000 - £10,000 to discourage “tyre kickers” if this isn’t allowed under the current legislation process then F.P.P should be brought in ahead of this #5 If there is a connection offer that is not getting the most economical connection due to “grid squatter” that customer wanting to proceed should have the right to have the details of the “grid squatter” who is blocking them or even better UKPN should be able to contact the “grid squatter” and state if they don’t progress with more payments within a month then they will lose their place


4

At any point back from pre F or pre adoption. The costs for a project are not settled at this point and invariably variations from UKPN and other contractors are coming in for a number of weeks / months post stage F. Also, DECC allow for eligible extensions which projects can apply for to extend those projects. The existing DG project customer could be given 90 days to accept and 6-9 months to build an extension. DECC eligible extensions expire post 12 months.

Q8.4.1 At which stage should released capacity feed back into the network (position A to E)?


Q8.4.2 Do you Have any comments or feedback on our Minded To Position for Releasing Capacity?

1 All developers should have an equal chance of accessing released capacity. The real question is what are you going to do to make that capacity available? What are you going to do to clear projects who have failed to get planning off the list? How will that knowledge become available in a timely fashion?

2 We appreciate there is no straightforward way to notify customers of released capacity other than through the LTDS and capacity maps, however, I do feel this is something that should be discussed at DG surgeries and discussed between UKPN and the customer through informal queries should the customer enquire and ask questions.

3 Not making the information available will likely put a time burden on UKPN project managers. I do not believe the information should be released in any forum including DG surgeries as it will give parties an unfair advantage. All capacity extensions other than that offered to existing projects (as in Q8.4.1 above) should only be tested via a new connection application or budget enquiry.

Lunch In the main restaurant, please reconvene at 2:00pm in the breakout session room

Life after ROCs Steve Carlow, Steve Foster, Jim Vasey




Questions

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1. Will the 2015 amendment of ROC incentives change the mix of generation technology?

2. How will the cessation of ROCs and switch to Contracts for Difference (CfDs) impact the overall uptake of DG?

3. How will Flexible DG Connections (assuming full roll-out) and ROCs together impact technology choice and volume?

Q&A Steve Bradley Head of Major Connections


Where are we now?

• Your views on seven key areas ☻Our Information Provision ☻The Application Process ☻Our approach to Charging ☻The Choice you have ☻Technical ☻Our Engagement with you ☻Overall level of Customer Service

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Where are we? What you have told us…

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10Information provision

Application process

Approach to charging

Choice you haveTechnical

Engagement

Customer Service

27-Feb-14

22-May-14

09-Sep-14


Reminders

• Next Customer Experience Workshop 26 February 2015

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• ENA DG Fora

Thank You

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