Regen’s response to BEIS’ REMA consultation:
a summary

Johnny Gowdy, director, Regen

Ellie Brundrett, project manager, Regen

Simon Gill, associate, Regen

Introduction

The current energy price crisis has exposed how our continued dependence on imported fossil fuels has increased the need for government intervention to subsidise fuel bills, while still causing devastation for many who face being unable to afford their bills this winter. At the same time, the scale of investment needed in all aspects of our electricity system to deliver on net zero power in just 13 years highlights the importance of focusing on delivery, and of de-risking the transition. 


Delivering an electricity system that can provide secure, affordable and zero carbon energy is critical to our future as a country. We need to do so in a way that is equitable and fair, supports a strong economy and makes use of regional strengths.


Get this right and we can deliver an energy system that makes use of renewable technologies for the bulk of our energy production, technologies that we know today are far cheaper than fossil fuels, and reduce our dependency on volatile international energy markets. It will also be one that brings together a raft of zero carbon technologies from battery storage, hydrogen and greater interconnection to ensure a secure supply.


Our wholesale market and the structures that go around it will play an important part in delivering the system we need. It will help incentivise investment in the right technologies, in the right places at the right time. It can help dispatch the resources we have available in an effective and efficient way. It can help make sure that prices reflect costs, ensuring that consumers benefit from lower cost renewable energy and that the bills they pay are predictable, fair and affordable. It should provide clear and consistent signals that give investors confidence that, if they invest to support the UK’s overall goals for our electricity system, then they can have confidence of making a fair return on that investment.

Market context

Our current wholesale market arrangements, based on a trading market introduced in 2002 and extended to Scotland in 2006, are far more complex, dynamic and advanced than is sometimes understood and, when digging into the details of the REMA consultation, our view is that the case for change has not yet been fully articulated and critically examined as part of this process of review.


There has been a tendency for some commentators and industry influencers to make general statements that the current market is broken or not fit for purpose and, while we agree that the current market arrangements require reform - and in some areas significant change - we do not see evidence the current arrangements are so far broken as to require a complete market restructure. Furthermore, existing mechanisms such as the Balancing Mechanism, Capacity Market, the Contracts for Difference (CfD) scheme and an evolving carbon trading scheme provide us with a wide range of options that could be expanded and adapted to support the net zero journey, without requiring radical upheaval and the introduction of a new administrative framework, all of which takes time to implement and could reduce investor confidence.


In part, the tendency to propose complex theoretical market concepts, such as a shift to Locational Marginal Pricing (LMP), stems from a lack of understanding of how the current GB market operates and a failure to identify the underlying cost drivers or causes of market inefficiency. There has been a tendency to skew the benefit case for market overhaul by taking a worst-case counterfactual – ignoring the potential for improvements within the existing arrangement (many of which are already in progress) and taking a rose-tinted view of a future theoretical arrangement. This may lead to REMA focusing on the wrong areas for reform and the wrong policy solutions. We would suggest that, after this consultation, there will be a need to re-evaluate the case for change in order to pinpoint the exact changes that are needed.


Market reform needs to be considered in conjunction with other key areas of reform:

  • A significantly greater role for strategic planning to create a net zero and energy security delivery plan, including an overarching system architecture and a holistic infrastructure investment plan.

  • Reform of network development and investment processes in order to deliver the transmission capacity increases urgently required.

  • Consideration of wider social and economic policies, such as judicious use of government spending, and the speeding up of planning and consenting.

  • A clear vision for how carbon pricing and trading will influence the electricity market. These are not separate markets and carbon policy can play a big role in delivering our net zero ambitions both within electricity and across the wider energy sector.

Figure 1: Any energy market reform must be considered within the context of the wider energy system


Recognising, therefore, that markets are just one part of a complex, evolving energy system, we feel that there is a need for an overarching Net Zero and Energy Security Delivery plan, which should include within it a detailed plan of how the electricity system will decarbonise by 2035 and how energy security will be maintained. We also recommend that the Net Zero and Energy Security Delivery Plan presents, at a high level at least, an overarching energy system architecture.


Having a clear view of this architecture, even if there are still areas of uncertainty, sensitivities and options to consider, will help the industry, policy makers, supply chain and investors to focus on delivery. It will help to move thinking forward, and away from the current tendency to think in terms of alternative, and often hypothetical, scenarios.  

Figure 2: Net Zero and Energy Security Delivery Plan, map of key elements


Scale and pace of investment needed

The biggest market challenge right now is to bring forward massive investment in low carbon technologies, flexibility assets and network infrastructure. Investment that will provide economic growth, energy security, lower energy costs and achieve net zero.


Events over the past year have raised the urgency of progress towards our net zero goals. Even before the current energy price crisis, the Government had acknowledged the need to reform our electricity system quickly. The 2021 Net Zero Strategy committed us to net zero electricity by 2035, reflecting the growing realisation that decarbonising our electricity supply will be a key driver in achieving our wider net zero aims: while today electricity accounts for 20% of our end use energy demand, by 2050 we expect it to be between 50 and 80% [1].


According to the most recent Future Energy Scenarios published by the National Grid [2], by 2035 we need to be delivering around 80% of our electricity from wind and solar in order to achieve net zero. That means an increase in renewable capacity of between 100 and 150 GW in 13 years, with build-out rates of between three and four times greater than those we have achieved over the past five years [3].

Figure 3: Historic installation rates for renewable technologies together with installation rates implied by the 2022 FES scenarios


Treasury analysis for the Net Zero Strategy has identified the need for £730 billion of investment to decarbonise the UK economy by 2037, of which £210 billion would be in the power sector. In addition to this, around £80-100 billion will be required to upgrade critical electricity network infrastructure. This investment significantly ramps up during the next decade and is a step-change on the current levels of investment [4]. More recent analysis from the CCC has highlighted that low carbon investment needs to reach £50 billion a year by 2030.  Achieving these levels of investment must be a key goal for REMA. 


Furthermore, the urgency posed by rises in energy bills makes the argument for accelerating the move towards net zero power more compelling. Renewables are substantially cheaper today than fossil fuel generators, with the most recent Government estimates of the levelised cost of energy putting wind and solar at less than half that of fossil fuels for projects commissioned in the middle of this decade [5].

Figures 4 and 5: Additional annual investment required to reach net zero, 2020-2037 (£bn, undiscounted 2020)


Our current CfD system, initially envisaged as a competitive support mechanism for technologies which were not yet fully mature, is now starting to deliver significant savings to consumers, allowing renewable developers to pass their lower costs through to consumer bills in return for the long term price confidence needed for investment. If we had been more ambitious with CfD auction capacity over the past few years, both consumers and the public purse would have seen even greater savings today.


Regen has supported the extension of the CfD scheme for variable renewable generation such as wind, solar and potentially tidal energy, calling for a much clearer long term strategy for renewable energy deployment and supporting the move to annual allocation rounds. This would send a positive signal to investors, allow developers to build their project portfolios, utilities to invest in grid infrastructure and supply chain companies to build the jobs, skills and capabilities needed to efficiently deliver net zero. We continue to strongly support the scheme, and the opportunities it represents, as evidenced by the latest allocation round securing renewable energy capacity that will generate electricity nine times more cheaply than current gas prices [6].  


However, as Regen’s analysis for The Day in The Life of the electricity system 2035 shows, renewables alone won’t give us the operability, flexibility and security that we need. Delivering flexible technologies at pace represents an even greater step-change. For example, while the battery storage sector has grown over the past few years and is now providing substantial support to the system through ancillary services, we need to move from a system which is installing a few hundred MW of battery storage per year to one that consistently delivers GWs of new capacity.


We will also need significant investment in new forms of low carbon dispatchable generation, including thermal generation with Carbon Capture and Storage and hydrogen-powered generation. While investment in dispatchable generation technology will require policy support, we do not believe that an extension of the CfD scheme to cover such dispatchable renewable generation would be appropriate, as this would incentivise such technologies to maximise generation and become baseload energy generators, displacing lower cost and lower carbon renewable energy. Market reform should deliver a clear business case and investment in these low carbon dispatchable solutions via other means, including capital investment, innovation funding, a regulated asset base and also through an enhanced Capacity Market.

Figure 6: Historic installation rates for battery storage together with installation rates implied by the 2022 FES scenarios


Principles for market reform

Market reform needs to support a step-change in investment in all zero carbon technologies and it needs to pass the cost-savings that come from a net zero power system through to consumers. This can be achieved if reform follows the following principles:

  • Remain laser focused on the objectives of net zero, affordability, security of supply and sustainable economic growth. Do not put these at risk by taking uncertain gambles on new theoretical frameworks that we are not confident can deliver. For any reform consider carefully the impact on the pace and scale of delivering each of the objectives.

  • Be very clear and explicit about the case for change. At present the case for change, in some areas at least, has not been well articulated and critically examined. There are certainly areas of reform that are needed, but the common perception that the “market is simply broken” has not been proven and in some cases is based on a misunderstanding of how the current market works.

  • Always put electricity market reform in the wider context of electricity system reform and take due consideration of the other key areas of development: strategic planning; network development; and wider government policy. At each point ask whether market reform is the best approach, or whether one of these other tools would be more effective. Where market reform is the best option, think carefully about how that reform will interact with each of the other areas of system reform.

  • In terms of prices and consumer bills: long term stable affordability should be prioritised over the promise of a ‘least cost’ pathway that entails significant risk of failing to deliver any of the elements of the trilemma.

  • As well as structural reform, REMA must consider the efficiency of the operation of the market and whether this can be improved. A recent study by LCP has identified that 51% of recent wholesale price increases could not be explained by the underlying supply/demand balance and bid fundamentals [7]. This implies that there is a significant amount of speculation, market sentiment and/or inefficiency in market which is driving up prices and costing the consumer billions. REMA should consider the operation of the market and what is driving pricing behaviour: forecasting, transparency, speculative behaviour, interaction with the Balancing Mechanism, liquidity, trading platforms, price triggers and the occurrence of bullwhip effects.

  • In electricity, networks are a prerequisite for markets. You cannot have an electricity market without an electricity network, and the design of the network has a major impact on how efficient the markets that use them can be.

  • Maintain confidence in investment, economic growth and the UK’s commitment to accelerate the transition to clean and secure energy.

  • Local energy systems and national energy systems are both important and should complement each other, each delivering on its own strengths whilst supporting the other with theirs. Wholesale energy markets and the bulk delivery of low carbon power are likely to work best at a national level, whilst reform of the demand side may be better achieved at a local level.

Summary recommendations for future REMA development

Our proposal for market reform is one in which we develop the existing electricity wholesale market at pace, but at the same time make meaningful changes to strategic planning, network development and wider societal, government and economic reform. This radical evolution of the electricity system and markets would represent the most far reaching process of reform since privatisation. The scale and pace of change is unprecedented. Delivering such unprecedented change carries risk – therefore, reform must look both to drive change and to manage risk. Rather than a single ‘big-bang’ change that would be high-risk, cause an investment hiatus and may be impossible to deliver, these reforms should be delivered as part of a controlled but major programme of change that could be rolled out within a 3-5 year period.


Delivering radical evolution requires strong, well-informed and strategic leadership at the centre of the electricity system. The complexity of the electricity system, the systemic uncertainty inherent in decision making, and the multiple objectives that we are trying to reach all mean that it critical that a full ‘system approach’ is needed.
In the past Regen has recommended the creation of an Office of Net Zero, or another integrated body, to be tasked with net zero delivery [8]. It may not be possible to create such an entity at present but there is a need for more integrated leadership across the FSO, BEIS and Ofgem, with the capability and authority to deliver the strategic planning and system architecture elements of system reform. Parallel policy initiatives should be clearly linked up and coordinated, or avoided.


In the modern energy system, which is far more decentralised and democratised, stakeholders from devolved governments, regions and localities must be fully engaged and their objectives recognised. The industry itself is also highly diverse. Therefore, REMA must continue to be transparent and multi-party; open to all and welcoming of challenge. This will not only help to ensure that the REMA design is fit for the future, but also that it can then be implemented.


Click the tabs below to investigate our recommendations for each of the key consultation themes. You can also read our consultation response in full here.

  • Strategic planning and investment
    • REMA must be aligned with the development of an overarching Net Zero and Energy Security Delivery plan. This plan should include an analysis of the key elements of the future electricity system; generation and demand growth, network infrastructure, flexibility, system balancing, capacity adequacy, curtailment and constraints, and projected energy and system cost.

    • This Net Zero Energy Security Delivery Plan should include an Overarching System Architecture which indicates the capacity of key technology types (generation, flexibility, interconnection and demand) with an indicative breakdown at a regional level.

    • Support this with wider reform of the planning system aimed at ensuring that networks, along with generation and flexibility infrastructure, can gain consent and planning approval in appropriate timescales.

    • Market reform must be backed up by the accelerated build-out of transmission and distribution network capacity. This could be based on a holistic network design approach to determine what network capacity is needed in ten to twenty years’ time and ensuring that Ofgem, NGESO (expected in the near future to become the Future System Operator, or FSO) and the transmission owners are resourced to deliver and held to account for failure. Support infrastructure decision making with a whole system cost benefit analysis (CBA).

    • REMA should, at least, consider the integration and interaction between carbon markets (carbon trading scheme, carbon tracking and the use of REGOs) as it will strongly impact and underpin the transition to net zero in the wholesale market.

    • Policies and programmes to deliver efficient use of energy will need to sit alongside wholesale electricity market reform rather than being a key goal of REMA itself.

  • Wholesale market
    • Maintain a national wholesale energy market that supports a varied and dynamic trading ecosystem that includes bilateral trading, a vibrant PPA market, organised power exchanges, forward contract markets and short term markets.

    • Increase the proportion of energy that is supplied on the basis of long term contracts including PPAs and those backed by CfDs (whilst maintaining appropriate marginal cost price signals to ensure optimal energy usage and flexibility).

    • Critically examine the operation and efficiency of the wholesale market and the occurrence of price speculation, uneconomic volatility, loss of liquidity, scarcity rent taking and bullwhip effects. Consider measures to bear down on these, focusing on transparency, forecasting, flexibility and liquidity.

    • Forward market liquidity should be addressed, for example by increasing the availability of longer term PPAs.

  • Locational signals
    • Do not pursue Locational Marginal Pricing either in nodal or zonal forms, since this will not provide effective locational signals and would significantly increase investment risk.

    • Explore the potential for a reformed TNUoS system to provide an appropriate long term price signal, which is properly cost reflective and has appropriate locational signals to influence locational investment decisions.

    • Explore ways to make transmission network congestion and the operation of the transmission network more transparent under a national wholesale market. This could include publication and mapping of congestion in real-time, network outage lists, and operational boundary transfer capacities.See, for example, Seven Solutions to Reduce Constraint Management Costs.

    • Consider the range of locational signals that currently influence investment decisions and whether these are consistent with an overall net zero system architecture and the delivery of the Net Zero and Energy Security Delivery plan.

  • Low-carbon investment
    • The CfD scheme could be enhanced, but overall it has been successful in bringing forward investment. It is also now transferring significant value from generators to consumers in the form of negative payments. Its use should be expanded, including increasing the frequency and amount of new capacity included in each allocation round and extending its remit to offer CfD-type contracts to existing variable generators. Auction rounds should be completed annually as planned, following the announcement by BEIS in February.

    • BEIS should undertake a full review of the CfD mechanism to better align it with future system challenges. This would include how it responds at times of excess renewable generation, the value of geographical signals and the creation of secondary CfD categories for targeted deployment.

    • Alongside CfDs, REMA should consider ways to encourage forward markets, for example by increasing the availability and use of long term PPAs and increasing forward market liquidity. PPA reform should look at the cost/complexity of the PPA market, the challenge of credit and their availability for small-scale and local generators. This will help to reduce energy costs, reduce market volatility and also encourage investment in low carbon renewables.

    • Do not incentivise dispatchable low carbon assets – such as by offering them CfDs – to become baseload energy generators and crowd out lower cost and lower carbon renewables energy. Do ensure that investment in low carbon dispatchable generation is supported via other schemes.

  • Flexibility and capacity adequacy
    • Ensure that the Energy Security Bill is not delayed further in its progress through Parliament and confirm the definition of energy storage in legislation.

    • Give the ability to prioritise low carbon ancillary services to the ESO and future FSO as soon as practically possible. This includes the creation of clear carbon reporting and setting emissions limits where feasible/appropriate.

    • Action needs to be taken speed up network connection processes for storage providers, as well as network investment. This might include reforming queue management processes, changing the way storage assets are modelled by network planners and looking at a range of alternative connection offers that could be made to storage providers.

    • Cap and floor funding model is not suitable for the support of low carbon flexibility in general but should be developed as an option for large-scale and long-duration electricity storage (LLES).

    • Extend and adapt the objectives of capacity adequacy to consider full energy system resilience and capability, aligned with an overall system architecture and requirements plan.  This includes reviewing the definition and requirements for future stress events, recognising that they are already becoming far more frequent, diverse and dynamic and will therefore require a range of responsive assets, flexibility and other market solutions.

    • Cease offering long term Capacity Market contracts to unabated fossil fuel assets and begin the process to move unabated fossil fuel assets out of the Capacity Market and into a Strategic Reserve, including the option to bring into public ownership. Focus the Capacity Market to support a new fleet of low carbon dispatchable generators including CCUS and Hydrogen.

  • Operability
    • The REMA team should quickly review the case for change to meet system operability challenges and whether these challenges and solutions (including the development of ancillary markets) should be progressed outside the scope of REMA by the ESO working with the DSOs and Networks.

  • Supplier obligations and Dutch Subsidy 
    • More long term clarity on the future role of energy suppliers in the future energy system is needed ahead of any new supplier obligation for either flexibility or the purchasing of low carbon generation being designed and implemented. When discussing flexibility in particular, lessons should be learnt from the delivery of the new Demand Flexibility Service from the ESO.

    • Develop a clear vision for how wholesale and retail markets will work together including a clear specification of the role that future supply companies will be asked to undertake.

    • We support the exploration of a form of Dutch Subsidy as a potential way of structuring support for investment in low carbon flexibility, but only to encourage the installation of smaller-scale, distributed assets and co-location.

Regen is a not-for-profit centre of energy expertise and market insight whose mission is to transform the world’s energy systems for a zero carbon future, offering independent expert advice and market insight on all aspects of sustainable energy delivery. We use our technical expertise, industry research and policy knowledge to support a range of public and private sector organisations to make the most of their clean energy opportunities.


Find out more by visiting our website.


References:

1 - Percentages calculated from the FES 2022 energy flow diagrams, NGESO, https://www.nationalgrideso.com/future-energy/future-energy-scenarios
2 - National Grid, 2022 https://www.nationalgrideso.com/future-energy/future-energy-scenarios 

3 - Regen analysis. Figures based on REPD (historical) and FES LtW, CT and ST.

4 - Treasury Analysis BEIS Net Zero Strategy 2021 supporting workbook, and CCC 6th Carbon Budget

5 - BIES, 2020 https://www.gov.uk/government/publications/beis-electricity-generation-costs-2020

6 - Carbon Brief, 2022 https://www.carbonbrief.org/analysis-record-low-price-for-uk-offshore-wind-is-four-times-cheaper-than-gas/

7 - LCP, 2022; “51% of price uplift is NOT explained by scarcity presented and bidding fundamentals” https://www.linkedin.com/posts/lcp-energy_power-gas-electricity-activity-6977959550620467201-SHop?utm_source=share&utm_medium=member_desktop

8 - Regen, 2021 https://www.regen.co.uk/download/energy-networks-for-the-future/


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