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Utility Week 13th October 2017

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12 | 13TH - 19TH OCTOBER 2017 | UTILITY WEEK Finance & Investment DNOs can't own storage in a competitive market Ofgem lays out its plans to encourage competition in flexibility and electricity storage services. Opinion Andy Burgess D uring the summer Ofgem and government pub- lished the Smart Systems and Flexibility Plan, which is a roadmap for developing a more flex- ible energy system in Britain. The benefits for consumers of a more flexible system are major – estimated to be between £17 billion and £40 billion up to 2050, according to research by Imperial College London and the Carbon Trust. We need to move quickly to adapt regulations and market arrangements so that they don't hold up progress on capturing these benefits. The plan announced several changes which will benefit developers of electricity storage. We also said that we want to see competitive markets developing for different forms of flexibility, including electricity storage services; and that the roles and responsibilities of the system and network operators were changing. Network operators will increasingly be buyers of flexibility ser- vices. This means they should not be looking to develop any new storage facilities of their own. Collectively they currently own around 13MW of storage. As distribution network operators continue to embed distribution system operator (DSO) roles, they will play an important part in managing supply and demand. The DSO will have to pick the most competitive option for addressing a constraint or bottleneck at any one point, choosing from a range of sources which include flexible generation and demand side response as well as storage. It is critical that DSOs remain impartial in the way they undertake their functions. If networks own and operate large amounts of storage, or for example if they use their own demand side aggregation services, how can people be confident that there is a level playing field and that the network com- pany will choose a more efficient alternative over an option they have an interest in? We are now setting out our initial plans for address- ing this alongside the detail of a modified generation licence for storage providers. Our view is that DSOs will not have to sell their existing storage, but they must be impartial when they operate it. The DSOs must oper- ate storage in a way that does not distort, or have the potential to distort, the market. We plan to introduce a new licence condition to ensure that the side of a DNO's business that operates storage of any size is legally separate from the part that runs the network. This will back-up existing requirements on ownership separation in European energy legislation and is in line with Euro- pean Union proposals for a Clean Energy Package. The DNOs will only be able to operate their own storage in very limited circumstances. For example, in a power outage DNOs could use batteries to keep vital substations, or priority customers, on supply temporar- ily until faults are fixed. This is in place of the mobile generators they would use at the moment. When the market is working normally they will have to get special consent from us that any decision to use their own storage is the most economic and efficient solution at the time. They would have to show us that there was no alternative storage available in the market and that other forms of flexibility would not have resolved a supply and demand management issue. Our aim is to make sure there is a competitive market in storage services. DSOs must carry out their role with- out conflicts of interest and if any further issues do arise we will take action to remove them. The principles that we are setting out on storage ownership and the dividing line between regulated monopolies and markets will continue to guide our regulatory approach more widely. We want to move quickly on resolving the owner- ship issue and finalising the generation licence for storage. This is important so that going forward there is no uncertainty particularly for new storage develop- ers. More than 550MW of storage has already contracted to come online by 2020, but this figure is set to grow rapidly. This makes it all the more important to have a framework in place that encourages competition in flex- ibility, including storage services, so that consumers can get the best value for money from the energy system. Andy Burgess, associate partner, energy systems

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