SR Response: Reformed National Pricing siting and investment levers consultation

On Friday, May 29, Scottish Renewables submitted our response to the UK Government’s consultation on Siting and Investment levers. The consultation was published alongside the Reformed National Pricing Delivery Plan and closed on June 2.

The consultation sought views on how policy levers can be reformed to support the delivery of the SSEP to reduce total system costs and consumer bills by influencing the location of new generation and storage projects in line with the SSEP’s requirements.

Scottish Renewables raised the following points on behalf of members:

• The SSEP should not be treated as a rigid or perfect blueprint. It will inevitably be based on assumptions regarding future demand, technology costs, project attrition and wider system developments. The framework should therefore provide clear strategic direction while retaining enough flexibility to respond to uncertainty and allow efficient projects to come forward.
• SR supports further development of options 2, 2b, 3 and a variant of option 4, which would apply locational charges differently depending on the technology.
• We do not believe locational charging should automatically be assumed to remain the dominant siting lever. Its role should depend on the wider RNP model adopted.
• The interaction between this consultation and Ofgem’s Call for Input on locational charging is fundamental. There needs to be greater alignment between Ofgem and the UK Government on this workstream.
• Overall, the framework should focus on reducing unnecessary risk, protecting the value of existing low-carbon assets, and delivering whole-system value for consumers while maintaining confidence in long-term investment.