Ofgem has opened a consultation on a rather technical but nevertheless important aspect of the ongoing madness that is net zero. As is the way of these things it runs to 83 pages, and can be found here. It seeks responses to ten specific questions, and allows only a month from the start of the consultation for submission of responses. I thought I should try to respond, since if people don’t show an interest, then Ofgem will feel free to carry on regardless (though I suspect it will do that in any event). Having ploughed my way through the whole 83 pages, and having realised that I am not qualified to respond in any meaningful way, I decided that my best strategy was simply so send them a broadside, expressing my discontent at the whole direction of what passes for energy strategy in the UK just now. I have probably wasted my time, but I felt it was the effort of letting them know that we don’t all support the expensive net zero project, and quite a lot of us are increasingly unhappy at the direction of travel. Given how much grief the new Labour government is deservedly receiving from sections of the media just now in respect of the imminent rise in the price cap and the removal of winter fuel payments from most old age pensioners in the UK, I hope that they are sensitive to complaints such as this. If not, at least I have marshalled some of the obvious arguments and rounded them up in one place. What follows is the text of my submission. If you want to do something similar you had better get your skates on – the consultation closes on Friday 30th August 2024:
I am responding to your Consultation on the proposed regulatory funding and approval framework for onshore transitional Centralised Strategic Network Plan 2 projects, dated 1st August 2024.
You say you would like views from people with an interest in development of the electricity transmission network and Net Zero, and that certainly includes me, albeit I lack the engineering qualifications to comment specifically on the various detailed questions you pose. I confine my observations, instead, to pointing out that Ofgem is seriously conflicted with regard to the obligations imposed on it by statute. Instead of continuing to pursue mutually contradictory objectives at significant expense to the customer and involving great harm to the environment, you would do better to speak truth unto power and point out to your political masters that the objectives they have set you cannot be met.
In your Executive Summary you point out that “Significant investment is required in the electricity transmission (ET) network to decarbonise the system and facilitate the transition to Net Zero. This is to enable connection of new renewable generation to the system, and to ensure the network has sufficient capacity to transmit the energy generated to where demand is located.” That has to be the understatement of the century. You repeat the statement at paragraph 2.3, following on from your noting that Ofgem has a statutory duty, under the Energy Act 2023, to support the government to meet its legal obligation to deliver Net Zero by 2050.
Yet you go further, and (Para 2.10) support the new Labour administration in its preposterous proposals to decarbonise the electricity system by 2030 – the 2030 Clean Power Plan (“CPP2030”). So far as I am aware, you are not (yet) legally obliged to support the plan. And yet you do, despite the fact that it should be obvious that the plan cannot be achieved and that a huge amount of money will be wasted in trying to achieve it. You say (paragraph 2.4) that “Historically, it has typically taken around 12 to 14 years to deliver large onshore ET projects, from conception through to commissioning” and go on to ignore the hard realities of the situation by supporting CP2030. Quite how the UK is to double onshore wind, triple solar power, and quadruple offshore wind by 2030 is something of a mystery given our performance to date with regard to timescales from conception through to commissioning. Furthermore, anyone with any experience in projects of this nature knows that trying to force them through in unrealistic timescales will multiply both costs and errors.
You ignore the fact that those countries with the greatest percentage of wind penetration in their electricity systems are also those with the highest household electricity prices. The UK has the dubious honour of having some of the most expensive electricity in the world, despite “leading the way” in rolling out wind farms.
Your press release of 19th August 2024 regarding the “Strategic Innovation Fund [SIF] to drive progress to net zero by 2030” says its projects “support efforts to end the era of high energy bills, excessive carbon emissions and energy insecurity by accelerating the transition to clean, homegrown energy”. Despite your role at the heart of energy policy you seem to fail to understand that this is a trilemma, a set of mutually contradictory objectives, a triangle that cannot be squared. We cannot drive down energy bills by making ourselves dependent on technology that works only some of the time, and requires back-up, whether from astonishingly impracticable and expensive numbers of batteries, or from gas-fired power stations, which have to be run inefficiently (and therefore more expensively than necessary) due to the subordinate role they are condemned to play. The Government’s own Levelised Cost of Electricity calculation acknowledges that:
While dispatchable technologies like CCGTs and CCUS generally help to reduce system costs, they run at less than maximum load factors and therefore their levelised costs increase. In these… scenarios, generally (but not always) the system savings outweigh the load factor impacts, resulting in an overall cost reduction. Intermittent technologies (e.g. wind and solar) generally impose a wider system cost, which is more severe in scenarios with lower flexibility or a less diverse generation mix……The value of additional CCGT capacity to the system is greater in scenarios where demand increases faster or there is a higher proportion of intermittent renewable capacity…
National Grid ESO’s Future Energy Scenarios, published in July 2020, indicated that the cost of reaching net zero in the UK’s energy network will be £3 Trillion or thereabouts, a cost of around £4,000 per household every year between now and 2050. Those costs might be buried in general taxation, or may be loaded on to the price of gas to pretend that electricity is relatively cheaper, or they may be borne by businesses (which will pass them on to their customers), but however the cost is distributed, it will be borne in the end by consumers and taxpayers. Quite how that ends the era of high energy bills is beyond me, and I suggest it should be beyond you too, yet you seek to accelerate the pain by supporting CP2030. I say businesses will perhaps bear some of the costs (and pass them on to their customers) but increasingly those businesses are not manufacturing ones. I note that for the first time since the beginning of the industrial revolution, the UK is no longer among the world’s top ten manufacturing nations. No doubt the price of electricity in the UK has more than a passing role to play in this regard – businesses lack the modest and inadequate benefit of the price cap “enjoyed” by domestic electricity consumers.
As for energy security, we seem to be importing more and more electricity via the interconnectors (I regularly spot imports of around 15% of our needs, and have seen them as high as 25%). The interconnectors on which we seem to be increasingly reliant are vulnerable to accidents or to malfeasance by bad actors (whether terrorists or hostile states). A few reminders might be in order before you continue down the road of more and more cables between various parts of the UK and from offshore wind farms to the main land. Numerous problems with the Western Link cable led to an Ofgem probe into what went wrong, and resulted in National Grid ESO paying almost £31m for wind farm operators to curtail output. At one point, average constraint costs arising from these failures rose to £6.1 million per day. Then there was the failure of the BritNed cable between the UK and the Netherlands in 2021. How about the failure of the Orkney-Pentland East cable (which cost £30 million)? One of the most spectacular and long-running failures was in respect of the Western Isles cable. Things have been so bad that in 2021 the company that owns the link to Gwynt y Môr wind farm argued that a series of repair outages required following a cable failure in October 2020 should be underwritten by consumers because insurers are leaving the market. The company noted at the time that the cost of insurance had risen 40 per cent in the past two years and many insurers were declining to provide cover.
I appreciate that interconnectors are generally promoted as an enhancement to our energy security by allowing the UK to export surplus electricity to the continent and by allowing us to import it when we are short. But a well-run system wouldn’t have regular surpluses and shortages that makes us dependent on offloading to, or importing from, foreigners. That isn’t what energy security looks like. The problem is compounded by the fact that as the UK’s electricity production is increasingly weather-dependent, it suffers from the fact that when it’s excessively windy here it usually is on the near continent too; and when the UK sits becalmed under an anticyclone so, often, do our European neighbours. This results in us seeking to offload our electricity when there isn’t a market for it, and needing to import it when it’s in short supply. As David Turver has pointed out:
We typically pay more than the market price for buys and accept less than market price for sells. Looking at the detailed data, the maximum purchase price was £6,599.98/MWh on 20th July 2022 when the reference price was £247.91/MWh. The minimum sale price was £-404.71/MWh on 29th May 2023 when the reference price was £63/MWh. It is also interesting to note that for the whole of 2023, the average sale price was slightly negative (£-0.22/MWh). These negative sales prices mean we paid others to take this electricity off our hands….Again, [referring to the graph accompanying his analysis] we can see the blue buy-prices are generally above the market reference price and the orange sell prices are generally below the reference price. In fact, for part of 1st December, we had to pay over £700/MWh for interconnector supplies when wind generation was low and demand was high. We also paid over £400/MWh on 6th December even though wind was generating over 6GW. Whereas, over the Christmas period we were paying people to take surplus generation off our hands…As we can see, most of the electricity sold is from 22:00-06:00. There is also a residual tail of sales from 07:00-14:00, reflecting the demand lull in the middle of the day. Most is bought in the morning peak from 05:00-07:00 and then again during the evening peak from 16:00-21:00…As might be expected we are selling most when demand is low and buying when demand is high, reflecting the fact that we are not really in control of generation and cannot use it to match demand….Even though the volumes sold during sleeping hours are high, the value of that electricity is low. In aggregate, the electricity sold during the middle of the day has negative value, so we pay others to take it off our hands. By contrast, we pay through the nose for the electricity we buy at peak hours.
Constraints payments represent another cost that only seems to grow, an inevitable consequence of increasing the number of wind farms without having in place an adequate system to cope with the wild fluctuations in power they generate. A couple of shocking news reports have come to light in just the last few days – the Scottish Daily Mail reported that Scottish wind farms have received £205 million in constraints payments so far this year, with £45 million being paid this month alone. Today the Shetland News reported that SSE “has already claimed more than £2 million in constraint payments this month and ahead of the multi-million pound project [Viking Energy on Shetland] switching on.” Ahead of its switch-on! How can that be?
In conclusion, you are presiding over the destruction of an energy system that worked cheaply and efficiently and its replacement by one that is inefficient, expensive, and dependent on the kindness (or avarice) of strangers and the weather. I appreciate that Parliament has imposed this destructive task upon you, but you do not have to be enthusiastic about an acceleration of the task that is not yet a statutory duty on your part. Until these basic points are addressed, Ofgem consultations will continue to amount to little more than an exercise in futility.
Climate Scepticism 
My goodness Mark that’s fearsome submission. Well done! I suspect they won’t reply – or, if they do, they won’t deal with your specific points. We’ll see.
LikeLiked by 1 person
Excellent response Mark!
I haven’t seen this being picked up by Net Zero Watch and others. Hopefully folk like Gordon Hughes and Michael Kelly are responding.
LikeLiked by 1 person
Brilliant Mark. It is impossible to believe that Ofgem do not perceive the “trilemma, a set of mutually contradictory objectives, a triangle that cannot be squared” which form the basis of their ridiculous report. It is inconceivable that they are not aware of the fact that Net Zero will decrease our energy security and drive bills ever higher, for the foreseeable future.
LikeLiked by 2 people
“Publication date: 01 August 2024” – “the consultation closes on Friday 30th August 2024″.
What a joke, railroaded spring to mind.
ps – Mark, ever thought about being energy sec – you would get my vote for your clear thinking/cut through the cr*p.
LikeLiked by 1 person
Note: this consultation is concerned only with ‘onshore electricity transmission projects’. Offshore projects add an additional raft of horrendous problems.
LikeLiked by 1 person
Mark,
Feel better now?
Have you ever heard of the practice of screaming at the sea? It’s basically what we are all doing here on Cliscep.
LikeLike
John,
Yes. Much better, thanks. Though give it a week and all the irritation with our foolish leaders will have built up again…
LikeLiked by 1 person
John,
LikeLike
truthfully honest and free of greenwashing bull shit – wake up people power poverty is coming and with it further destruction of ecology and habitats
LikeLike
That telt them.
LikeLike
A great response, Mark. 👍
“As David Turver has pointed out:
We typically pay more than the market price for buys and accept less than market price for sells. Looking at the detailed data, the maximum purchase price was £6,599.98/MWh on 20th July 2022 when the reference price was £247.91/MWh.”
Energy Live News reported the maximum price paid was £9,724/MWh
https://i.postimg.cc/VNcH5cj3/temp-Imageqf-QWu-H.avif
(PostImage used to produce links as *.jpg, but now they’re *.avif and I’m unsure if the latter ‘open’ properly when posted in a comment.) The source of that £9,724/MWh now appears to be behind a paywall)
LikeLiked by 1 person
Send this to the newspapers…
LikeLike
Excellent reply Mark. I think our population needs to wake up to the nature of the ruse that our governments are playing. The best explanation I know is of, “mass formation”, used by governments apparently for hundreds of years to manipulate their citizens. It is best explained by its researcher, Mattias Desmet, psychologist, of Ghent University, Belgium. See several interviews of him on YouTube, and his book, “The Psychology of Totalitarianism”.
LikeLike
So much for Ofgem. They have been played for the fools that they are by unscrupulous parasites. Their reward for rank incompetence is to be given ever more responsibilities and bigger budgets by governments of all stripes:
“Newly Opened Viking Wind Farm taking nearly three times its CfD Price in August 2024”
https://www.ref.org.uk/ref-blog/382-newly-opened-viking-wind-farm-taking-nearly-three-times-its-cfd-price-in-august-2024
Read it and weep.
LikeLike
Mark – thanks for the link, partial quote –
“We estimate that Viking has earned over £10m in this month alone, when it would have only received about £3.5m if it had been paid under the CfD and had not been constrained. This implies a staggering price of about £199/MWh, as opposed to the already generous CfD price of £67/MWh.
These facts make a mockery of claims that projects such as Viking offer good value to consumers, or, as Viking’s launch publicity claimed, that this would one of the most productive onshore wind farms in Britain. On the contrary, it is shaping up to be one of the most heavily constrained, least productive and yet extortionately profitable wind projects ever built.”
BBC news had a short TV report on this the other day & webpost – ‘Windiest part of the UK’ could power nearly 500,000 homes.” but for some reason never had the renowned “verify” team check the facts beyond the (cut & paste) Viking press release.
LikeLike
Dfhunter,
Of course the BBC doesn’t report on the scandal that now surrounds Viking Energy and SSE – that would be so damaging to the narrative, which pretends (untruthfully) that Ofgem is effective at looking after consumer interests; that renewable energy is cheap; that lots more of it will reduce our energy bills; and that decarbonisation of the grid by 2030 is feasible and can be achieved without blackouts or other difficulties.
LikeLiked by 1 person
I have today received an email from Ofgem, regarding their consultation, to this effect:
Due to a number of respondents expressing their concern that the duration of this consultation period would not provide sufficient time to provide a response, we have re-opened the consultation and extended it by an additional two weeks from the original closing date. We consider that this amended timescale strikes the appropriate balance between allowing respondents adequate time to respond to the consultation and ensuring that we are able to meet our wider duties and objectives.
Consequently, it seems that anyone wishing to respond to the consultation now has until 13th September to do so. As I say, I received the email only today. If they went public with the 2 weeks extension only today, then almost half of it was over before people were made aware of it, which seems a bit poor, to say the least.
LikeLike
Note to Ofgem – well worth a read:
“Relying on electricity interconnectors adds to market risk”
https://watt-logic.com/2024/09/17/relying-on-electricity-interconnectors-adds-to-market-risk/
LikeLike
“Energy experts call for Whitehall to correct ‘preposterous’ renewables claims”
https://static1.squarespace.com/static/656f411497ae14084ad8d03a/t/66e93796bcf7e65482b51981/1726560151377/letter+to+pocklington+signed.pdf
Dear Mr Pocklington
We thought it important to bring to your attention what we believe to be a serious issue with
DESNZ’s Energy Generation Costs 2023 report. As we are sure you understand, the numbers in this
paper are central to assessments of the cost of delivering Net Zero.
The report claims that by next year, the cost of electricity from newly commissioned offshore
windfarms will have fallen to £44/MWh. This is hard to square with the recent CfD awards at
£82/MWh.1
The reason is that DESNZ’s figures appear to have no grounding in empirical data. This is clear from analysis of hard data – namely the audited financial accounts of offshore windfarms, and the
metered output data held by Ofgem.
According to DESNZ’s underlying assumptions:
offshore windfarms is over £3 million per megawatt. Thus DESNZ’s figure may be understated by a
factor of 2.
operate. Recent offshore windfarms have been averaging around £160,000 per megawatt in their
early years of operation – around four times as much.
windfarms shows that this is not true. Even with the most optimistic assumptions, the cost will
average over £200,000 per megawatt over a windfarm lifetime. Thus DESNZ’s figures are likely to be
understated by a factor of 5.
‘capacity factor’). The fleet average capacity factor has been around 40% for many years, and only
rising very slowly.
that assumption to be incorrect. Capacity factors of all wind turbines decline steadily, and larger
turbines decline more quickly than smaller ones. A lifetime average capacity factor might only be
around 35%
The levelised cost of offshore wind is probably the single most important input into estimates of the cost of Net Zero. With DESNZ’s figures, we would need to spend around £600 billion on offshore windfarms by 2050. Using real-world costs and efficiencies, the spend might rise to £1.2 trillion. In our view, that difference, or more than half a trillion pounds, cannot be allowed to stand.
We would like to suggest that it is in the best interest of the public that these figures are corrected
as a matter of urgency,
Yours sincerely,
Andrew Montford
Director, Net Zero Watch
Gordon Hughes
Emeritus Professor, University of Edinburgh
LikeLiked by 2 people
Small point: the fleet average capacity factor and the capacity factor of a new windfarm are not going to be the same, with the new turbines being larger.
That said, the rest of the points seem to be valid, as far as my limited knowledge goes.
LikeLike
I despair:
“Pylons and solar farms the cost of lower bills – PM”
https://www.bbc.co.uk/news/articles/cd7x5y95pppo
Does he really believe that? If so, he’s not fit to be in charge of the country IMO.
LikeLiked by 1 person
“Do our leaders understand the power grid at all?
It seems as if basic facts are being completely ignored”
https://thecritic.co.uk/do-our-leaders-understand-the-power-grid-at-all/
...To the unaware, references to the unreliability of renewable power sources aren’t interpreted as an attempt to anchor the discussion to an indisputable fact; it’s interpreted as a dog whistle to people who are wrong and bad and dangerous. It’s the equivalent of saying “I’m not racist, but…” but for energy policy. It’s a verbal signpost to anybody who considers themselves forward-thinking or progressive that they don’t need to listen any further, and that the person they are talking to is a crank or a wrong ‘un.
Instead, the fact must be stated, directly and clearly, again and again, every time the subject is addressed. And it must be impressed upon the general public, until those who would prefer that people didn’t know about it are forced to come out and try to deny it. Currently, among the elite, our fact can be ignored by those who want to ignore it because it is politically tainted and low-status. It’s a fact that populists and sceptics talk about, and can therefore be dismissed as fake, or as some kind of conspiracy theory.
However, if the public can be made to understand that loading the grid with intermittent power sources without backup means regular blackouts, and that backing up the British grid with batteries would cost at least the equivalent of the UK’s whole annual national income, and that backing up the intermittent sources without batteries (in the absence, at least, technologies that are hardly conceived of yet) means ramping up diesel generators and producing enough CO2 to render the whole exercise pointless, it will put the burden on those who think that it’s a good idea to go through with it in the next few years to justify themselves.
If the next leader of the opposition were to actually grasp this issue properly, they could lead, if not quite a revolution, then perhaps something a little like it.
LikeLiked by 1 person
In my submission to Ofgem (above) I included reference to David Turver’s excellent analysis of the costs associated with our increasing dependence on interconnectors, and occasionally selling to (absurdly cheap) and regularly buying from (absurdly expensively) electricity from our European neighbours. This is the result of relying on unreliable renewable energy. It arises from the madness of thinking that we can sell electricity to our near neighbours when we have a glut (that’s when they probably have a glut too) and buying it from them when we have a shortage (because that’s when they probably have a shortage too). That’s so obvious I should have thought a five year old could understand it. However, some people see things differently:
“Brexit has put £370m a year on price of power from EU since 2021, experts say
Trade body Energy UK also estimates total energy cost of leaving bloc could reach £10bn by end of decade”
https://www.theguardian.com/business/2024/oct/25/brexit-has-put-370m-a-year-on-price-of-power-from-eu-since-2021-experts-say
The body which makes the claim is one which is up to its neck in pushing renewables, so it’s hardly likely to admit that over-reliance on renewables is the problem. The “about” section of its website
https://www.energy-uk.org.uk/about-us/
describes Energy UK thus:
We are the trade association for the UK energy industry with over 100 members covering the breadth of the sector including suppliers, generators, aggregators, flexibility providers, electric vehicle charging operators and software companies.
We work with the sector, government, regulators and wider stakeholders to champion a sustainable UK energy industry.
The claims made in the article are actually worth reading, for they amount to an admission that renewables and the net zero agenda are the problem (while seeking to put the blame on Brexit):
…“Unless the UK moves toward closer cooperation with the EU on energy and climate it may lead to additional costs of up to £10bn this parliament through higher energy bills and lower Treasury revenues,” it said….
…It also estimates a further £800m in carbon tax charges the EU plans to introduce on imports from 2026.
According to its analysis, the Treasury will lose between £900m and £2.4bn in revenue a year as a result of a reduction in demand for UK energy that new emissions trading rules are expected to trigger as the EU implements its carbon border adjustment mechanism in 2026.
It notes the UK is likely to become a net exporter of electricity by 2030, but that the new carbon tax barriers “will make it harder for the UK to fulfil its potential”.…
How the Guardian justifies its headline is also a mystery. The report actually claims:
…It calculated that energy trading outside the bloc was costing the UK £120m to £370m a year….
That is categorically not the same as £370m a year.
LikeLike
“Britain’s green energy pledge ‘credible’ if planning fixed, says system operator
State-owned Neso says Britain could be net exporter of green electricity by end of decade at no extra cost”
https://www.theguardian.com/business/2024/nov/05/britain-green-energy-system-operator-neso-green-electricity
highlighting this:
The ambition will also require the market for flexible power demand – typically asking consumers to shift their use from times of high demand – from about 2GW last year to between 10GW and 12GW by 2030.
It shouldn’t need stating, but this isn’t what energy security looks like, nor do superpowers endure such constraints. Yet Miliband is quoted as saying:
“This independent report provides conclusive proof that the government’s clean energy superpower mission is the right choice for the country, replacing Britain’s dependency on volatile fossil fuel markets with clean, homegrown power controlled in Britain…“
I try not to be rude about people but on this occasion I am struggling with that. It’s difficult for me to understand how anyone charged with the nation’s energy security can read the report and arrive at that conclusion, not least in the middle of a dunkelflaute that is causing power cuts and sky-high electricity prices, with gas generators doing all the heavy lifting.
Surely if ever there were a time to re-evaluate the rush to decarbonise the grid, it’s now.
LikeLiked by 1 person
I could have posted this in a few places, but given that the interconnectors aspect featured in my submission to Ofgem, perhaps here is as suitable as anywhere. As always, it’s an excellent piece from Kathryn Porter, and well worth a read:
“Challenging the myths of the renewables and interconnectors model”
https://watt-logic.com/2024/12/09/renewables-and-interconnectors/
LikeLike