We welcome the opportunity to respond to this consultation and commend Ofgem for bringing forward a consultation on the pressing topic of local energy governance reforms. However, we would like to note that there has been some difficulty in replying to the questions on regional system planning due to the high-level nature of the current proposals. The lack of clarity about the role and remit of the Regional System Planner (RSP) provides scope for multiple interpretations of the proposals, particularly in relation to how the RSP role would develop holistic, cross vector regional plans. It is unclear if this would be through regional optimisation of existing planning processes (gas and electricity Distribution Future Energy Scenarios and Network Development Plans); or if the RSP would seek to carry out its own analysis, in which case the networks could expect to have a much reduced planning role as investment decisions would be informed by regional plans. Both of these options would need changes to the regulatory frameworks for the distribution companies, so we welcome the accompanying consultation on Future Systems and Network Regulation.
Although there is ambiguity on the role and structure of the RSP, we support the overall vision for the consultation and propose that a number of design principles should be maintained regardless of remit. Specifically: