Change in Generation Connections Environment
NIE Networks and System Operator Northern Ireland (SONI) Joint Statement - 17 November 2015
This is a joint statement from NIE Networks and SONI in response to the recent change in the generation connections environment resulting from Utility Regulator Determination (DET-572), which concluded that NIE Networks was not entitled to insist on grant of planning permission as a pre-requisite for applying for connection. As a result, NIE Networks has changed its application policy to align with this determination.
Following NIE Networks’ statement on 12th August 2015 implementing this change, an unprecedented volume of new applications has been received. This includes 47 new Large Scale Generation (LSG) and 242 new Small Scale Generation (SSG) applications.
A total of c836MW of generation is already connected to the NI grid with a further 676MW already committed to connect. This is a significant achievement noting that, in 2014, NI had the highest renewables level (in MW per customer) anywhere in the UK. The recent applications total around 880MW of additional new generation capacity (LSG and SSG) i.e. more than already connected, with the majority received over a two week period. This represents a significant step change in the connections environment.
The geographic spread of applications is province wide and the provision of access will impact all areas and require investment in both the distribution and transmission networks, leading to possible significant investment costs which may be socialised across all NI customers.
The current connection policy applied by NIE Networks and SONI is that each connection application is assessed on an individual basis, sequentially in application date order. Given the level of grid congestion, both distribution and transmission assessments will be required to determine the impact of these applications.
The planning permission prerequisite previously employed by NIE Networks resulted in a manageable programme of applications allowing progressive design iteration, and also removed the scope for speculative applications. Both of these benefits have now been removed resulting in large volumes of applications within a very short time.
LSG and SSG applications are integrated in a single enlarged generation queue and are interdependent in terms of network impact. These applications impact on both the distribution and transmission systems, which are already heavily saturated due to the level of generation presently connected or committed to connect. There are already significant levels of congestion at a number of bulk supply points.
This means that to progress the LSG and SSG applications, a significant number of individual distribution connection designs and associated transmission assessments must be completed before it would be possible to determine network limitations and develop efficient and appropriate network investment proposals for connection. The transmission assessments are particularly complex because of the scope for interaction between individual applications and would require years to complete if the current sequential assessment methodology were to remain in place. This timeline is clearly unsatisfactory for issuing connection offers to developers.
The current approach would not allow NIE Networks and SONI to develop the overall transmission and distribution networks resulting from the recent exceptional influx of applications in an efficient and coordinated manner in line with our legal obligations and would result in an increased burden on the NI customer base. Hence, an alternative approach is required.
NIE Networks and SONI have been working closely since August 2015 to understand what alternative approaches might be considered and what the optimum approach may be. However, it is clear that whatever method is adopted, it will not be possible to issue connection offers for this recent influx of applications within the current Licence standard timeline of 90 days.
NIE Networks has therefore engaged with the Utility Regulator around this matter, providing evidence of the issues highlighted above and has sought extension from the requirement to issue offers within the current 90 day Licence standard, in order to enable a workable and acceptable solution to be developed. The Utility Regulator has agreed to an extension of time in relation to NIE Network’s obligations to issue offers for an initial period to 31 May 2016 on the basis that NIE Networks and SONI continue working to resolve this situation in a timely manner.
In light of this extension, NIE Networks points out that those developers who made applications from 12 August 2015 may have to wait some time before a connection offer is issued. This extension would apply to both current and future connection applications. However, in the event that it is possible to do so, NIE Networks will endeavour to issue offers before the above date.
Going forwards SONI will consider valid transmission applications as part of the integrated queue (i.e. transmission and distribution queue combined).
In addition, even when new arrangements are developed, the present volume of applications is likely to pose a challenge to the timely provision of connection offers. NIE Networks and SONI also understand that imminent changes to NIRO incentive arrangements for onshore wind could also have a significant impact for applicants.
It would therefore be expected that in light of the uncertainties set out above, parties will consider whether they wish to proceed with their application or withdraw from the connection process. We would therefore anticipate early engagement with applicants to understand how they wish to proceed and agree an appropriate procedure to confirm the volume of connection applications that would fall under the new connection offer arrangements.
NIE Networks and SONI understand the uncertainty caused by these recent developments and a worskshop will be held at 2.00pm on Wednesdsay 16th December at the Stormont Hotel. This workshop will be chaired by the Utility Regulator propose to arrange a workshop in December 2015, which the Utility Regulator will chair, and will outline in more detail the options for, and to seek views on, potential alternative approaches from the impacted parties.