SGI Response to CRU Discussion Paper on PR5

Last update on March 10, 2020.

SGI Response to CRU Discussion Paper on PR5

Date: 12th March 2020
SGI Response to CRU Discussion Paper on PR5

Dear Mr Lindsey

Smart Grid Ireland (SGI) with offices in Dublin City West and Belfast welcomes the opportunity to respond to the CRU discussion paper on the approach for Transmission and distribution Price Review 5 Electricity Networks 2021 – 2025. Smart Grid Ireland is an independent industry led networking cluster influencing government and regulation, promoting good corporate citizenship and actively driving technology solutions that accelerates the cultural and societal changes needed to achieve a digitalized, decentralized and decarbonised electricity network and improve the Island of Ireland’s international competitiveness.

In pursuit of these objectives the cluster provides an Industry / Grid Transformation Forum to engage with Utilities, System Operators, Regulators and both Governments. Support the EU Directive on energy security & sustainability and take a long-term, stakeholder centric view of the system in transition and creating the potential for demonstration project opportunities.

Smart Grid Ireland welcomes the clarity and emphasis of the CRU discussion document in support for the Climate Action Plan (CAP) and the Clean Energy for all European Package (CEP) underpinning the government’s transformational roadmap for economic growth and future development of the Irish economy in which decarbonised energy supply and security is a transformational building block.

Section three of the document sets out CRU’s intention to develop a regulatory framework that facilitates and delivers transformational change. While we see this as a journey without an end point, SGI supports the Regulatory approach in taking into consideration future energy business models. people and energy – the role of society as well as energy and infrastructure. Social objectives have expanded and become more complex, especially around climate change and resilience.

Recognizing that digital technology can’t do everything, we recommend that the regulator look at structures on improving the consumer interface between supply side, the Grid owner (ESBN) and the end customer. It is our opinion that utilities struggle to find the right digital self-service formulae for end users. The question might be - who is the conductor of the energy supply orchestra, so that all the instruments play in harmony. We support the regulators intention to provide the appropriate level of oversight with dynamic monitoring and reporting during the price review period. However, new opportunities have emerged for utility service improvement and value creation, but structural limitations prevent adaptation and utility evolution. SGI would encourage reimagining of the Utility framework – New Business models for a new age and reimagining regulatory approaches for power sector transformation. Business model innovation is needed to capture value and answer the question how do we buy energy in the new smart future?

New service capabilities, combined with changing customer expectations, create expansive new business opportunities, In regards to greater risk and reward we support the regulators plan to move utilities along the services spectrum from a price risk situation with the customer towards a financial price and service risk with business. SGI supports the regulators objective to transform the role of the DSO and TSO to be fit for the future with new energy business models being developed leading to energy policy and regulation delivering to people and society in a new carbon-net energy environment.

In relation to security of supply the transition towards more renewable energy and diversified supplies is creating opportunities as well as challenges for the security of the energy infrastructure. As renewables are now part of the energy portfolio and are rapidly gaining market share, they bring along benefits such as energy mix diversification, with distributed generation growing at a fast pace with installed capacity expected to more than double in the next decade worldwide. At the same time, as the energy generation portfolio transitions and diversifies further, new challenges are emerging, which require changes to the electric utility business model and regulatory policies to ensure secure and reliable supply.

Research by Imperial College, London for the UK government suggest that up to £21bn of new value is available to electricity utilities per year by 2050. This can be achieved by reshaping and redesigning regulation:- Ref: Dr Jeff Hardy - (User-centric) UK Zero Carbon Energy Futures.

  • Change what we regulate: normalise electricity through redesigning the market
  • Change how we regulate: change from regulating process to regulating for risk
  • Protect and serve consumers better: create one essential service consumer regulator
  • Open up to retailers: risk assure retailers rather than license suppliers
  • Optimise the system: opening up system data for the public good
  • Get more from less: redefine and recalibrate security of supply

Within the government policy mix published in 2019, it is essential that ESBN are empowered to deliver on the government CAP and CEP targets for the consumer making it easier for consumers to produce, store and sell their own energy effectively through participation in energy markets.

Digital disruption is creating new opportunities – but also threats. On the one hand, technology is instrumental for realizing intelligent systems and interconnected assets; on the other hand, it introduces new threats such as the possibility of cyberattacks. The increasing interconnectivity and proximity of energy systems means that conflicts can have ripple effects on energy markets and prices. New technologies, such as batteries and grid-embedded generation, are making the cybersecurity of grid systems more vulnerable.

We welcome the regulators policy of stakeholder and customer engagement as an important phase in the ongoing work of transforming traditional energy supply models and we look forward to participating in these going forward. SGI aims to contribute towards the deployment of highly decarbonised electricity grid on the island of Ireland by 2030 that meets the national policy targets. It is essential in the meantime that ESBN and the CRU are adequately resourced to make the step changes necessary within the time horizons mapped in government legislation. As an all island representative cluster we seek to collaborate, inform, connect enable and stimulate Ireland’s economy by supporting the decarbonisation of the economy allowing energy industries and innovators expand their businesses and grow employment opportunities.

Thank you for the opportunity to contribute to the PR5 discussion and I trust that you will find our comments useful and give your consideration to the recommendations outlined.

Yours sincerely

Bob Barbour
Secretariat for Smart Grid Ireland
& Acting CEO

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