Grid capacity constraints and connection delays are severely limiting renewable generation capacity across all parts of the UK. This is hindering local authorities ability to increase local renewable energy generation at a critical time, and ultimately achieve their net zero objectives. Plans for new housing and new jobs are also often derailed as a result of grid constraints.
Despite the significant implications the grid can have on local delivery of net zero many councils have had limited engagement in discussions about where and how to reinforce or change the electricity network infrastructure in their areas.
Ofgem, the energy market regulator, has recognised this and intends to introduce Regional Energy Strategic Plans (RESPs) as a means to ensure local democratic participation and coordination in regional energy infrastructure planning.
However, some important design decisions remain which Ofgem is currently consulting on, with a response deadline of 8th October 2024, and through this blog we intend to explain what decisions remain, and strongly encourage local authorities to have your say through the consultation.
The need for RESPs
When considering creating the RESP role, Ofgem said:
“As the energy system undergoes the transition to net zero, we will see accelerated decarbonisation and decentralisation of generation and demand. Accommodating the transformation of the ways we generate electricity, heat our homes and power our vehicles will require changes to how the energy system is planned and operated at the sub-national level.
To deliver this transition effectively, it is imperative that key energy system functions are performed by institutions with the competence, appropriate skillset and incentives to drive net zero at least cost, and that there is clear accountability and coordination. These changes are in flight at the national level, and must also be reflected at the local level.”
In July 2024, Ofgem launched a consultation into its proposed Regional Energy Strategic Plan policy framework. The framework highlights the important role that RESPs offer local authorities in supporting a more strategically planned energy system, with democratic representation and accountability at its core. They should enable planners to create a clear roadmap for how local energy systems need to develop to reach net zero
RESP consultation
The consultation is seeking input from local authorities on the function, governance and boundaries for RESPs.
Ofgem have proposed that GB be split into 11 RESP regions: one for Wales, one for Scotland, and nine for England. The regions will align to local authority boundaries, rather than to the current DNO (Distributed Network Operator) areas.
Each region will have a Regional Energy Strategic Plan (RESP) that will be responsible for developing a strategic plan in that region, that is fully cognisant of the regional context and challenges.
Ofgem will introduce a governance mechanism for RESPs that embeds democratic representation and accountability within the process. The current expectation is that each RESP will have a Board comprising both democratic and ‘technocratic’ representatives to ensure local authority voices are heard along with those of DNOs, National Grid, etc.
UK100, and many of our members, believe this is a positive and necessary change to the way that electricity network planning is undertaken. We are of the view that having councillors and officers who are at the sharp end of the energy challenges involved in strategic planning will challenge energy system participants to find more ambitious and innovative solutions.
But although the RESP concept has been committed to, the design is still being developed. Two key outstanding decisions that will be of interest to local authorities are: what the regional boundaries will be; and the regional governance arrangements.
RESP boundaries
For England, Ofgem initially proposed that the RESP boundaries should align to those of the “sub-national transport bodies” (STBs). They believed that these were the most established and optimal archetype, covering the whole of the country, cross-vector in nature, aligning to democratic boundaries and operating at sufficient scale.
However, Ofgem thought that two of these areas - Transport for the North and Midlands Connect - might need to be subdivided further, and were amenable to other changes proposed by local authorities with experience of these bodies.
Some local authorities have expressed concerns about the use of the STB regions. STBs do not generally have a strong identity beyond transport matters, and in areas with two tiers of local government there is little or no engagement with district councils, who are important players in the energy system.
In the south-west, for example, some councils were of the view that the South-West Councils region (roughly the combination of the Peninsular Transport and Western Gateway STBs) had a stronger identity and history of cooperation and would be a better candidate for the RESP region. Ofgem agreed to recommend this as their preferred alternative.
RESP governance arrangements
The other major design consideration for RESPs is how local authorities and other actors will be engaged in the RESP governance.
Ofgem’s proposal is for a single “strategic board” to convene local authorities, delivery partners (e.g. network operators) and other relevant local actors in each region. This board would: provide oversight of RESP development, including technical oversight; facilitate transparency and increase visibility of regional priorities; and produce a recommendation on key decisions being made.
However, Ofgem does not propose that the strategic board would have the final decision-making role in ‘signing-off’ the strategic plan, a role which some had called for.
In terms of local authority representation on the strategic board, Ofgem proposes that upper-tier authorities in England (including combined, county and unitary authorities) and unitary authorities in Scotland and Wales have representation on the board. However, the suggestion is that combined authorities would act as representatives for the upper or lower tier authorities they serve.
While for lower-tier authorities that are not part of a combined authority, Ofgem suggests that the National Energy System Operator (NESO, the accountable RESP Delivery Body) would work with local authority stakeholders to develop suitable representative arrangements.
Conclusion: review proposals and respond
As indicated above, we believe that the creation of the RESP role is a valuable improvement to electricity system planning which will give local authorities a much stronger voice in delivering the network improvement necessary for them to achieve their own net-zero, housing and employment objectives.
But we also think that it is important for councils to review the more-detailed design proposals currently being consulted on by Ofgem (here).
We suggest that the main areas that LAs might want to review and comment on are:
- Does the proposed RESP region, and the other Local Authorities that would comprise it, seem acceptable and sensible? (See section 5 of consultation document)
- Do you agree with the proposal for an ‘embedded’ strategic board (integrating technical actors and members with a democratic mandate), although without the final decision-making role in ‘signing-off’ the RESP? (See section 4 of consultation document)
- Do you agree with the proposal that upper-tier authorities (where not part of a combined authority) and combined authorities would be directly represented on the strategic board, with lower-tier authorities to develop suitable representation arrangements with NESO, the RESP Delivery Body? (See section 4 of consultation document)
With less than a month until the consultation closes, on 8th October 2024, the time is now for local authorities to engage in the design and implementation of the RESP policy framework to ensure they have a strong voice in future strategic energy planning.
