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UTILITY WEEK | 10TH - 16TH FEBRUARY 2017 | 21 Operations & Assets Analysis T he publication of the government's and Ofgem's joint call for evidence on the transition to a smart, flexible energy system was protracted and painful. Waiting six months for a solution is one thing, wait- ing so long for talks about the problem is another. The premise for such a discussion was sound. Acting to facilitate change in one area without fully considering the knock- on effects in another is a recipe for disaster, hence electricity storage's wait for even the most basic regulatory changes. But industry responses to the consultation reveal a desire for less talk and more action. Storage features less prominently in responses than might have been expected, being surpassed by a greater focus on the transition to a distribution system opera- tor (DSO) model and preparing for the rise of electric vehicles (EVs). Neither the gov- ernment nor Ofgem should be surprised to find network operators pressing ahead with major work programmes without waiting for them to finish chewing the cud. The electricity storage sector has long been vocal on the regulatory issues holding back adoption. Accordingly, consultation responses largely repeat well-worn argu- ments that are largely accepted. The only point of conflict is over whether distribution network operators (DNOs) should be allowed to own and operate storage. This point draws into question whether Ofgem is really willing to listen to the evi- dence it has collected. In a column written at the time of the call's publication, Ofgem associate partner Andy Burgess set out the regulator's thinking and made its position clear: "We don't think network companies need to own or operate storage, because it might stifle development of competition in the market." Instead, Ofgem proposes that DNOs pro- duce heat maps to show where connecting storage would be of most help to the over- all network. However, that does not mean those locations will be the most profitable, and responses make it clear the industry is unconvinced by this approach. Networks understandably want assurance that their balancing needs will be met by a competitive model before they are frozen out of the market. And the storage industry itself also disagrees with Ofgem. The Electricity Storage Network says DNO ownership would drive deployment in the short- and medium- term. According to National Grid's Future Energy Scenarios 2016, DNOs could account for as much as 85 per cent of electricity stor- age capacity. Several ideas have been proposed about how to protect a nascent competitive market while allowing DNOs in, including applying safeguards set out in the Winter Package for Europe. Another proposition is to adjust the innovation component of the RIIO price con- trol to allow DNOs to "prime the pump" for a limited time before market-based deploy- ment for storage takes over. At one time electricity storage was the disruptive technology to watch, but atten- tion now is moving on to the next technology in the pipeline. Given the pace of regulatory change for storage, stakeholders can be for- given for wanting to look further ahead. The rise of the EV is a prominent concern in the responses, and it is clear industry wants preparations to start as soon as possible. The Energy Networks Association (ENA) calls the rise of the EV a "significant and near-term challenge" and says the develop- ment of technology and commercial stand- ards is necessary to enable visibility and control of smart charging. Already the ENA has carried out a high-level assessment of the potential impact of EVs on network investment. It encourages the government to "co-ordinate an approach to accessing EV charging infrastructure that meets the needs of the industry and consumers". Innovate UK is also calling for govern- ment support in the development of vehicle- to-grid charging technology to enable the market to overcome the significant design challenges in developing low-cost, compact and low-power vehicle-to-grid charging for domestic use. Forward thinking now would also allow technology developers to take advantage of the techno-economic opportu- nity for small-scale renewables and plug-in vehicle charging systems to be linked. This would cut investment costs through the shar- ing of DC-to-AC inverter hardware. The barriers to both of these markets are clear. Of greatest concern is the evolution of the distribution system operator, and the balance between necessary diversity due to geographical differences, and consistency for technology developers. All major issues raised by respondents, from the adoption of renewable generation to the distribution charging model, will require greater clarity on the form of the DSO. Rather than wait for a regulatory lead, the ENA chose the close of the consultation to launch a major programme of work, the TSO-DSO project, to facilitate co-ordination between DSOs, the system operator and transmission operators in delivering effi- cient network planning and system-wide use of resources. In doing so it may provide the solution to many of the issues Ofgem and the government plan to spend the next few months considering, stealing the resulting roadmap's thunder. All talk and no action Industry responses to a call for evidence on smart energy systems put EVs centre stage, as well as an urgent need for clarity about the role of any DSO. Lucinda Dann reports. The ENA's TSO-DSO project 2017 workstreams 1. Transmission-distribution process – development of improved T-D processes around connections, planning, shared TSO/DSO services and operation. 2. Customer experience – assessment of the gaps between the experience customers currently receive and what they would like, and identification of any further changes to close the gaps. 3. DNO to DSO transition – development of a more detailed view of the required transition from DNO to DSO including the impacts on existing organisational capability. The aim is to deliver a clear and agreed DSO/SO model with accompanying roles and responsibilities for market participants (TO, DNO, SO).