Written evidence submitted by Paul Richardson (GRI0085)

By Paul Richardson, member of Community Energy Group in West Devon, and presently designing charge-control technology for domestic off-grid storage batteries.

Abstract:

Failures in policy and regulation cause surplus electricity generation to be discarded whilst the local population experience energy poverty: an example from SW England.

1: As of spring’22 the South West Electricity Distribution Region has more renewable generation each year than it imports from the National Transmission Grid. That sets precedents for

•        how GB handles an increasing renewable proportion in the energy mix

•        what will occur as GB reaches Net Zero

2: The SW region is 3 times oversubscribed for renewable generation. Despite this, it continues to receive applications from renewable energy companies who wish to install more solar farms, wind turbines and commercial storage batteries.

Ofgem announced a Strategic Code Review for Access Charges (03may22) which requires DNOs to no longer charge 3rd-party connection applications for any part of the grid enhancement costs which are a consequence of that connection. Only the physical connection itself is chargeable.

The result is a continued increase in planning applications, which may not legally be rejected by the LPA or National Grid Electricity Distribution (NGED) for reasons of existing over-capacity. This places an unacceptable financial burden on consumers who have no right of appeal.

The SCR was announced after Ofgem had published its decision on the Costings and Conditions for NGED’s RIIO-ED2 Agreement (Apr’23 – Mar’28). Therefore NGED has no funds to provide the required infrastructure upgrades.

Consequently NGED now needs to raise additional money by increasing the Distribution Use of System (DUoS) charges and Daily Standing charges to consumers.

3: Large Generators (>1MW) connecting to the grid at 33kV and above, are required to be controlled by Active Network Management. ANM uses a licensed radio network to curtail grid export during times of surplus generation. Generation sites with earlier connections have higher priority than those implemented at a later date.

Electricity generation from wind & solar plants is discarded automatically by ANM commands. That is unacceptable in a region with high levels of energy-poverty.

There is an obvious alternative, which is to store electricity in batteries during impending surplus periods, but DNOs themselves may not own or control generation or storage assets.

There is a need to incentivise local Councils, and thereby consumers, to facilitate the installation efficient battery storage, proportional to the energy surpluses in their area. The decisions need to be devolved away from Central Government to those with local knowledge.

4: Nodal/Locational Pricing needs introducing as soon as possible. Using electricity close to the point of generation diminishes the requirement for widespread grid upgrades. That reduction in costs is what allows the end-user price-per-kilowatt to be beneficial to both parties.

It is important to create a price-model which is aligned to the geographical area where the renewable generation occurs.

There is little point, for example, in offering Nodal-price discounts to consumers in Bristol to combat surplus wind-generation on the South Wales coast. That electricity would in any case still need to be passed through the 400kV National Grid link running across the Severn estuary.

Nodal pricing must limit the number of transformers through which the electricity has to pass before reaching the consumer.

Nodal pricing tariffs must be universally accessible, including to those households with pre-payment meters and to customers on commercial tariffs, such as farms.

Nodal pricing structures are a modification of the Time-Of-Use tariffs as already offered by Octopus Energy. All Energy Suppliers must offer ToU & Nodal tariffs within a year.

Energy-mix forecast for East Yelland BSP on which Nodal Pricing can be based

A Node should be defined as the area served by a Bulk Supply Point (BSP). There is already a substantial amount of data  available on the capacity and energy-mix for each BSP area, and that allows Energy Suppliers to incorporate that forecast data for a BSP into their Billing System.

The example above shows six areas served by BSP transformers in North-east Devon and Somerset. Those at Bridgwater and Taunton are sited alongside Super-Grid transformers connecting to the 400kV Transmission Grid.

Topography, weather conditions and electricity generation sources differ between BSP areas, but are more homogenous within each area served. East Yelland has substantial wind generation on high ground facing west, whilst more solar farms are found in Tiverton BSP area. Each area is a major electricity exporter when weather conditions dictate.

Ofgem needs to resist calls for Nodal Pricing to be based on the Grid-Supply Point which serves a property. That might be easier for Energy Suppliers, but it would make the areas larger than is reflected in weather conditions, and be less effective at handling times of excess generation.

Moreover, by the time over-supply gets constrained by the GSP transformer, it will already have saturated the Distribution Grid (132kV and below). That’s too late to tackle the problem, and would still require excessive infrastructure upgrades.

5. Xlinks proposes bringing a 1MV DC undersea cable from Morocco, thereby importing valuable electricity from wind and solar sources.

The projected cable capacity is 3.6GW. That is more than the 3.26GW potentially available from both turbines at Hinckley-C

However, Xlinks intends landing the cable near Bideford, in the SW Region, which is already experiencing over-supply from renewable assets. The proposed grid-connection is on the ‘wrong’ side of Hinckley.

Whilst the UK requires Moroccan energy, SW England does not. If it is landed in Devon, consumers would need to fund substantial grid upgrades to carry the electricity eastward from Alverdiscott GSP.

In financial terms, why is it not preferable to land the undersea cable at Seabank GSP near Bristol? The consumers in SW Region would not then have to fund extensive land-based cable upgrades.

Decisions of national importance must still be subject to local conditions. This is increasingly the case as we use greater proportions of electricity from localised renewable sources.

Planning regulations need expanding to provide Local Authorities with mechanisms to refuse permission when the area is faced with significant over-generation. If there is no possibly remedy within 2 years of a decision being given, then permission should be withheld. To do otherwise allows Applicants to hold Planning Consent as a company asset, but with no installation proceeding.

That is akin to Land-Banking, but with renewable energy generation potential instead of land.

6. Grid Topology

For the past 100+ years, the electricity grid has been based on the need to transfer energy from a few large power stations to customers across the country. The greater the distance from the central mass of generators, the higher was the daily standing charge.

The Distribution Grid was perceived as ‘the problem’. It took a lot of money and effort extending the xylem as far as St Ives and Na h-Eileanan an Iar. But most of the ‘clever’ engineering was being done in the roots and the trunk.

Over the last 25 years, the tree has begun to change.

Realising the enormous potential of energy becoming available at the far ends of the distribution branches, we’ve formed committees, commissioned reports and decided to reinforce the trunk!

Why?

➢        Because that’s how we synchronise to the 50Hz grid frequency

➢        Because that’s what the financial model was built on

But look at it the other way around.

If the industrial revolution had instead given us ‘green’ energy technology, then the resulting organism would look very different.

It’s more akin to a mycelium or a neural network, and it’s more resilient to failure.

If our Future Energy Strategy isn’t moving towards that sort of ‘biological grid’, then we’re probably doing something wrong.

Is it that the financial security of the energy industry has become more important than the technology required to deliver the energy itself?

7. The Resilient Grid

New technology must strengthen the ability of the grid to resist outages through mechanical faults and cyber attacks.

Fully autonomous smart control is essential to achieve that…

… and that must be built on the foundation of Smart Meters which are properly implemented.

Within the UK Smart Meter Network the commands being sent to consumers and generators are encrypted and secure. But our implementation of Smart Meter technology is woefully inadequate. Its principle purpose has been to generate income to energy companies, rather than offer the features required to benefit the wider population and the economy.

In March 2023, DESNZ has published a report Delivering a Smart and Secure Energy System, based on consultations by BEIS during 2022.

The report proposes extending the deployment of Energy Smart Appliances (ESAs) beyond EV Chargers to Heat Pumps, Storage Radiators and Heat Batteries.

There is to be new legislation to

•        ensure that ESAs are used flexibly, with tariffs promoting Demand Side Response

•        develop ESA standards, ensuring interoperability, and based on PAS 1878

•        accelerate the growth of Time of Use tariffs with access to the tariff via the internet

The report proposes to extend the mandatory requirement for Smart operation beyond the installation of EV Chargers.

But our existing implementation of EV chargers is not a sound platform on which to model future smart technology. Domestic EV Chargers are not actually ‘smart’ at all. Their ‘smartness’ is imposed on them by being under control of the Energy Suppliers.

As such they barely comply with the EV Charging Regulations, Sections 10 and 11.

Permitting domestic Energy Suppliers to further develop and implement Imposed Smart features is detrimental to end-users. It places even more power in the hands of energy companies who are no longer trusted by the wider population. The 2022 energy crisis has destroyed their credibility.

Alternatively, UK-developed Smart Technology which uses Autonomous Smartness embedded within the device, will create a global demand for British energy products.

Use of Internet-borne commands, and ignoring the encrypted Smart Meter communications technology, in the drive to promote widespread uptake of ESAs is also counterproductive. We lose the very resilience which we seek.

Auxiliary Load Control Switching (ALCS) is the correct method for implementing ESAs.

The preferences are set by the customer, but the commands to implement those are sent through the Data Communications Company to the customer’s Smart Meter.

The Smart Meter ensures that the ESA (charger) is turned on/off in accordance with the time periods of each customer’s Time-of-Use Tariff. It is the only method which ensures that customer billing is correct and legally-sound.

Without ALCS, the Government/Ofgem is exposed to legal challenges for institutionalised over-charging.

Why does the DESNZ strategy embrace only heat-emitting technology?

Because that was dictated in the questions asked in their survey.

There is precious little evidence that the heat-based strategy will better use the growing proportion of renewable energy or provide a more robust energy delivery system.

Since the very nature of a heat-pump is that it should operate continuously, it is difficult to imagine why DESNZ imagine that there is any benefit in making it ‘smart’.

8. The Smart approach to a Flexible Grid lies in the use of battery storage to capture electricity from renewable generation sources when it is available.

To ensure that the Appliances can continue to operate during a grid outage, they should be run ‘off-grid’ rather than ‘grid-tied’.

A Grid-tied battery installation is the most common method.

✔ It can be charged from the grid and from solar-panels with a string-inverter

✔ The same consumer unit (fuse box) is used to connect the inverter and battery to all appliances

✔ The battery will first supply appliances in the home, then export to the grid

☞ Requires permission from the DNO and product certification for grid connection

✘ If there is a grid-outage, neither the solar inverter, nor the storage battery can operate. They rely on the grid to provide the 50Hz synchronisation.

✘ Requires configuring to pick up the low-cost periods of a Time-of-Use tariff (although later models should be able to do this automatically in future).

An off-grid battery installation:

✔ Battery can be charged from the grid or solar panels using the same hybrid inverter/charger

✔ Appliances supplied from the off-grid consumer unit will still operate during a power outage

✔ Additional battery storage can be added as required

✔ More inverters can be added to provide additional power to appliances

✔ Does not require consent from DNO

✘ Requires a separate consumer unit and additional mains wiring

Off grid battery installations are more often found amongst crofter communities or installed on a partial DIY basis. A qualified electrician is not required to install the battery and its wiring.

An off-grid installation can

•        accept surplus electricity from the grid when there is over-supply

•        protect the grid from demand-surges

9.  Adding EV Chargers, PV Panels and Heat Pumps to the grid has consequences.

Grid losses are increasing, mainly due to phase imbalance, and harmonics fed back from heat-pump compressors.

These adverse effects have been accelerated due to 25 years of Government subsidies, but it is the DNOs who are required by Ofgem to clean up the mess. Financial incentives don’t overcome the need to comply with the basic rules of physics.

The UK must tackle losses and outages due to Phase-Imbalance and Harmonics (increasingly caused by Heat Pumps). Energy loss at local substations is currently running at 10%.

Adding a high-current appliance to a house with a single-phase supply means that the return path to the substation transformer uses the Neutral wire.

The Neutral is not fused and some older cables use a thinner wire, which suffers thermal stress. Underground cables were not designed to carry these loads and can fail.

10. Towards a more flexible future

More innovation

Less control over energy developments by central/national organisations

and no control of renewable/storage assets from outside the UK!

Less dependence on an always-on grid supply

Renewable energy doesn’t work like that

We require greater resilience against cyber attack

Greater emphasis on local solutions which:

•        take into account generation sources within the area

•        use more storage to reduce surges on the grid

Allow Local Planning Authorities to reject sub-optimal projects

Once a renewable energy resource is utilised, then it is accounted for.

You can’t have another go with rival technology.

August 2023

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