Opinions and Papers

These papers are distilled dispatches from the energy frontline. None of the collations of notes and materials below is intended to indicate that legal materials needed to make an assessment are complete. No legal advice is offered in providing these materials.

They are, however, food for thought.


The Price Crisis - (August 2022)


THERE ARE REPORTS of crowds outside Ofgem’s offices in London and Glasgow, gathered to protest against the fact and operation of the price cap.


Ofgem in its defence argues that prices are out of its hands, that the cause of the problem is gas and the rise in gas prices is driven by the war in Ukraine and (but to a much lesser extent) by increased...


Being Specific - (July 2022)


LAST June, the Climate Change Committee published its annual Report to Parliament, Progress in Reducing Emissions*.


Over a month later, the decision of the ‘Client Earth’ judicial review was published.**


The judicial review involved a back and forth about the legality of the government’s Net Zero Strategy (NZS) with reference to two provisions in the...


Counting To Zero - (May 2022)


I HAVE PREVIOUSLY REPORTED on the connection problems for batteries. Many battery projects won’t be able to connect for the next six-to-eight years from today.


This moratorium on connecting batteries is not local. It is widespread.


The cause of the delay is that National Grid says it must reinforce parts of the transmission system before more plant can...


PROGRESS TO NET Zero? - (Aril 2022)


LAST OCTOBER the government announced key policies for net-zero—updated by it in an APRIL policy paper.*.


The policies involved revolve around five themes: offshore wind, onshore wind, solar, hydrogen and networks/flexibility.


The hydrogen targets, aims and ambitions have been outlined before++ and there is little more to be said of them. But what of the rest?


Ofgem on Storage - (February 2022)


IN THE SUMMER OF 2021 the government published a slew of policy papers, all intended to increase system flexibility. This was recognition that intermittent generation (solar and wind) is predicted to increase substantially (a handwave at ~300% per technology isn’t out of place)*.


Yes, the policies were thin on detail and thick on the 'we hope to'. But still, they were policies with a flexibility end-goal.


Ofgem’s latest ‘minded to’ publication (see later) does...



Supporting Intermittency - (October 2021)


THERE ARE TWO main reasons, it is claimed, why more onshore wind plant isn’t being built:


  • the planning system is tilted against the technology (and probably has been ever since Eric Pickles was accused ‘buying’ votes by stalling the approval process); and


  • they aren't cost-effective, i.e., they don’t have a predictable level of income for capex and opex costs.


RenewableUK aims to tackle these issues in its new...


CfD Strike Prices - (September 2021)


THE NEXT CfD AUCTION opens in December. It is intended that twice as many CfD contracts will be awarded in this auction than were awarded in the last one.


Each of the technologies eligible to enter the auction is in a 'pot'. Each pot has limitations placed on it.


  • Pot 1 is solar, onshore wind and hydro. All three together have an aggregate budget of £10 million and each of onshore wind and solar have a cap of 3.5GW.


  • Pot 2 is floating offshore wind, tidal, wave and geothermal. They have a dedicated £55 million budget with £24 million of that earmarked for...

The Hydrogen Strategy - (August 2021)


MUCH OF THE TIME when talking about some aspect of the government's net-zero strategy, it has seemed best to put the 'strategy' part of that phrase into scare quotes just because it normally fails to provide enough to count as a strategy or to be taken as a realistic route forward.


BEIS’s recent UK Hydrogen Strategy* essentially consists of lists—lists of decisions yet to be taken or lists of things yet to be done, often by others, often seeming to expect that others will take part voluntarily. And it is hopeful, but not sure, that its...


Flexibility on Slow - (July 2021)


GOVERNMENT gets flexibility – that it is essential for an electricity system with increasing numbers of small, intermittent, renewable generators that are set to grow by 300% (give or take a fairly large amount) per technology. (That excludes offshore wind, because it feeds onto the transmission system.)


It also gets the associated need for the digitalisation and interoperability of assets to facilitate flexibility. That is to be achieved to a substantial extent by means of (involuntary, or automatic) Demand Side Response through centralised assets switching other assets on or off. This is DSR on a far bigger scale than...


Keeping Unabated Gas - (June 2021)


THE CARBON TRUST, working with the Imperial College team whose study on batteries was embraced by government almost as soon as it was published, has produced a report called Flexibility in Great Britain*.


The report outlines a number of different ways of reaching the 2050 zero-carbon target and the costs of doing so.


It goes without saying that it argues for flexibility as the key to keeping down costs. We've known that for some time. In the last five years smart meters...


Online Supply - (May 2021)


THE GROWTH of renewables kick-started a process that is transforming the old-style supplier-customer relationship. There are so many small (and not so small) generators seeking to sell their output and they are, for the main part, agnostic about who they sell it to and even more agnostic about how they sell it. ‘Revenue stacking’, or sales of output in timed ‘tranches’ which yield multiple income streams, is becoming something that all renewable plant looking for the best return needs to consider.


The changes begun by the growth in this sector have helped to break the market power of the Big Six. But at the same time, the proliferation of generators has clogged up the...


Electricity Market Reform - (April 2021)


THE OLD electricity system was centralised: big plant sent power to the transmission network where it was ‘thinned out’ through substations before being sent on to the distribution networks.


The growth of renewables has changed all this. These schemes are (mainly) relatively small and they mainly (excluding offshore wind) connect to the distribution network, bypassing the...


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