Below are our responses to the questions included in Appendix 4 of the consultation document.

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1 Electricity Market Reform (EMR): Potential synergies and conflicts of interest arising from the designation of the Great Britain (GB) System Operator (National Grid Electricity Transmission plc) as delivery body for the proposed Capacity Market and Feed-in-Tariff Contracts for Difference (FiT CfDs) Response by RenewableUK Introduction: A number of unknowns related to Electricity Market Reform (EMR) make commenting on the proposed plan jointly presented by Ofgem and DECC a challenging exercise. Despite this, RenewableUK has made its best effort in not only identifying problems, but offering possible solutions to meet Government s outlined goals. As mentioned in the letter from Martin Crouch and Jonathan Brearley, there will be conflicts of interest arising from designation of National Grid as the delivery body for the proposed Capacity Market and FiT CfDs. We appreciate the opportunity to offer suggestions of how to mitigate these conflicts so that EMR can be successfully implemented, keeping efficiency, security of supply, economic growth, consumer costs, and sustainability top of mind. Checks and balances throughout the system, Chinese walls, and regular updates being made publically available are crucial to minimise any conflicts of interest involving National Grid as a privately owned company, ultimately responsible to its shareholders. EMR will not be without flaws once it is enacted into law, which makes it even more important to ensure reforms are heavily scrutinised by multiple stakeholders getting it as close to perfect as possible and then to undergo regular reviews to determine whether it is working properly. It also requires oversight and transparency as part of the process to avoid missing the objectives set out by Government. Below are our responses to the questions included in Appendix 4 of the consultation document. Q1: Please provide your views on the synergies that may arise given National Grid s proposed functions as EMR delivery body. Q1a: Please be a specific as possible as to what these synergies will be, how you consider they may arise, and how customers may benefit. Q1b: Please provide any views you have on how these synergies could be maximised and what evidence would support the existence of synergies and enable analysis of their benefit. Despite there being real concerns about conflicts of interest, as outlined by Ofgem and DECC, as the current System Operator (SO) National Grid is potentially well positioned to fulfil the role of EMR delivery body given its skills and available resources. Potential synergies as described in the letter are only possible as long as the roles and 1 of 5

2 accountabilities of the Government, delivery agent, and Ofgem are more clearly outlined and defined than presently. In addition, every step of the way the process should be made transparent and ring-fencing should be enacted. National Grid s knowledge of current technical and transactional mechanisms could allow it to proceed as delivery body with a more holistic view of generation and transmission, the ability to avoid unneeded duplication, and the capability of identifying future constraints within the system. At the same time, there should and would be constraints to the kinds of information freely available between different arms of National Grid. Additionally there should be caution when considering possible efficiencies to the system; with efficiencies come winners and losers. It should not be National Grid s role to choose winners especially when it has the potential itself to gain. Q2: Please provide your views on the conflicts of interest that you consider may arise given the new information that National Grid Electricity Transmission plc may have access to and the influence and discretion it may have under proposed EMR responsibilities. Q2a: Please be as specific as possible as to what these conflicts of interest will be, how they will arise, your views on the potential materiality of them and how they may lead to customers detriment and impact on effective delivery of EMR. Q2b: What evidence would support the existence of conflicts of interest and enable analysis of the problem? Potential conflicts of interest stem from National Grid being both the Transmission Owner for England and Wales and the Electricity SO for England, Wales and Scotland, in addition to its other interests such as the carbon pipeline, interconnectors, gas transportation, and Carbon Capture and Storage businesses. Despite National Grid already having to adhere to regulatory requirements these will need to be reinforced and strengthened through ringfencing to ensure National Grid does not promote the technologies where it has a financial interest. Transparency throughout the process, including regular reviews, is paramount to ensure a fair playing field and to encourage investment from other players. Reviews from Government should be held on a regular basis and outside stakeholders should be given an opportunity to request such a review if deemed necessary. It is unclear what consequences DECC and Ofgem have in mind if it is determined there have been abuses. Despite intentional abuses being unlikely, without consequences there is little to prevent abuses from taking place. Therefore, it is worth exploring what penalties are most appropriate. It is worrying that there is still uncertainty in what National Grid will be solely responsible for in administering contracts and auctions, in addition to its role in relation to the counterparty for the Contract for Difference, causing serious problems. As it stands it is only known that the SO will have some operational independence to implement schemes set up by Government. Once finalised, the required criteria for FiT CfDs should be made crystal clear to everyone so that it is evident whether or not the criteria have been met by the party attempting to enter into the contract. If National Grid is to have discretion, that should be shared in detail as soon as possible to more effectively examine the potential conflicts of interest and synergies. It is RenewableUK s position that the delivery agent should have very little discretion and when it does, its internal thinking should be made transparent to everyone so that investors have certainty as to the types of FiT CfDs that will be approved. Such an arrangement of making criteria 100% clear would give added certainty to investors. However, even with clear criteria, a question arises of where would a generator turn if it had 2 of 5

3 objections to the use of any discretion available to NG? Would there be an appeals process? It should be agreed that a lengthy and costly process should be avoided and the best way of doing so is to have set criteria that are black and white to everyone involved. This transparent arrangement inhibits National Grid as delivery body from exercising unnecessary influence over the system and eliminates a large portion of potential conflicts of interest. National Grid should not be in the business of picking and choosing winners and should instead focus on administering the mechanisms to meet objectives set by Government. Such a scenario based on administration and transparency could be trusted by investors enabling them to more accurately assess the risks and returns of projects seeking financial investment. Q3: To the extent that you consider conflicts might arise, what measures do you consider would be most appropriate to eliminate, or reduce to an acceptable level, these conflicts? Q3a: Please be as specific as possible, identifying where possible which mitigation measures are appropriate for which specific conflicts of interest. Given the potential conflicts of interest, on the face of it full ownership unbundling of the System Operator is an option that should be considered. A fully independent body administering the FiT CfD and capacity mechanism would avoid uncertainty, confusion within the market and questioning of National Grid s motives, instead creating an even playing field for all players and clearly preventing conflicts of interest. Set against this, full ownership unbundling may be overly complex, expensive, and time consuming. We recognise that the benefits of this option would have to be clearly greater than other options to justify such an intervention, but it should not be ruled out without thoughtful consideration. Such a full ownership unbundling would take considerable preparation and arguably takes more time and resources than available. Given this, RenewableUK would favour careful legal unbundling and ring-fencing of the System Operator to be enacted in addition to requiring complete and total transparency throughout the system, as long as it can be demonstrated that this option delivers a similar outcome to full ownership unbundling in terms of disinterested exercise of the SO s EMR decision-making discretion. Q4. Are there ways in which the design of the delivery arrangements for EMR, for example in the design of the relationship between Government, National Grid and Ofgem, could mitigate any potential conflicts of interest? In the Planning our electric future: technical update published December 2011 it mentions that the SO must annually report its progress against the delivery plan to Government, but it seems more sensible for National Grid to report back on a quarterly basis and that be made publically available. By requiring the SO to report back on a more regular basis this reduces the risk of National Grid having information at its disposal that is not available to other outside companies. RenewableUK recommends that related modelling techniques be made available in an open source format so that anyone interested is able to evaluate and scrutinise the information. By making information such as the amount of capacity that has been contracted for under the Capacity Market and the amount of capacity being developed under FiT CfD publically accessible it would also make the market more efficient and indicate to interested parties where opportunities exist. In the technical update it is also mentioned that National Grid as SO will solely take on the task of creating a draft delivery plan to be approved by Government. However, at the 27 March joint Ofgem-DECC workshop on this issue, it was announced that after Government sets objectives and criteria National Grid will merely provide analysis (on, inter alia, technology costs, deployment potentials, capacity forecasts and requirements, impacts of 3 of 5

4 different scenarios on bills, Government objectives, system costs), which DECC would use to create the Delivery Plan. Further clarification is needed as this development is a significant change from what has been previously shared. It is worth mentioning that National Grid is not in the business of power generation and therefore would not be adequately qualified to supply reliable cost figures and deployment potentials, as recently suggested by DECC. It seems to be more appropriate to have a transparent panel of experts including National Grid and others putting together a draft delivery plan that could have a public consultation and then be shared with Government. Input from generators should be specifically sought out, as they are better positioned to offer insight into the costs of deployment. Government could then analyse the recommended path forward before offering a revised draft for comment. Alternatively, if DECC creates a Delivery Plan on the basis of evidence and analysis provided by the SO, then this plan must be subject to public consultation. It is important Government not be too reliant on any one source of expertise and should take advantage of its own expertise in addition to other stakeholders. DECC seems to have left the door open on this issue in the technical update by stating that they could convene a panel of experts to provide further input as well as performance review meetings. However, such a panel should be required instead of the mere possibility, in addition to establishing the frequency of the review meetings. Open consultation on the draft Delivery Plan would also allow others to share their expertise and opinions. The absence of National Grid in Northern Ireland leads to a number of hurdles to overcome as to how it could act as EMR deployment agent there. For example, National Grid may not be able to access all the information necessary to make appropriate decisions. Other complications include the difference in legal environments requiring a separate contract with separate criteria, a different strike price taking into account difference between SEM and BETTA, and the non-existence of the Balancing and Settlement Code (BSC) intended to manage the FiT CfD counterparty agreement. Further adding to the complexity is the fact that unlike Great Britain there is a long queue for grid access in Northern Ireland. With Connect and Manage in Great Britain, developers are assured of timely connections, but in Northern Ireland there is no such guarantee, raising questions of if/when there is little FiT CfD volume left by the time generators are able to connect. At what point will developers be eligible to sign onto a contract? And how will National Grid effectively manage this process? Q5: Do you think there are any areas of discretion in decision making that National Grid Electricity Transmission plc may have under the EMR role that give rise to specific areas of concern? Q5a: Please specify what these areas are and why they give rise to concerns. It is still unclear whether National Grid will be given a role in determining the type, location, and volume of new generation connected to the system. If this is the case, it would raise serious concerns as it is very different from the system currently in place and would warrant further scrutiny. There is concern that DECC may be relying too heavily on the expertise of National Grid. It is not prudent to be overly dependent on one particular entity, especially when they have something to gain from the process. National Grid and other stakeholders have a valuable role in structuring the future electricity market, but it is equally important that DECC has the personnel in place with the degree of technical expertise working on behalf of the Government. In addition to industry stakeholders it may also be appropriate for DECC to enlist the assistance of academic expertise and outside consultancies. 4 of 5

5 For further information please contact: Gordon Edge RenewableUK Director of Policy Tel: James Hubbard RenewableUK Economics Policy Officer Tel: of 5

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