Incentives and Opportunities Signalled by Transmission Charges in Scotland. Iain Wright 03 September 2018

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1 Incentives and Opportunities Signalled by Transmission Charges in Scotland Iain Wright 03 September 2018

2 COMMON WEAL is a non-profit think-anddo tank based in Glasgow which campaigns for greater social and economic equality, environmental sustainability, democratic participation and a higher quality of life based on an All of Us First approach. It was founded in 2014 and has since produced high quality, research-based policy proposals across a broad range of topics such as housing, energy, finance, social security and local democracy. For more information on Common Weal Policy visit allofusfirst.org/policy or craig@common.scot

3 Author Iain Wright's work in the electricity industry spanned 35 years, working in Scotland and Ireland. From an initial role as a civil engineer maintaining hydroelectric assets for the state-owned North of Scotland Hydro-Electric Board, Iain had later roles in retail energy supply, wholesale electricity market design, generation economics and regulation, in the private sector.

4 Contents Introduction page 01 Principles of network pricing page 01 Locational signals in existing Transmission network use of system (TNUoS) charges page 01 Responding to locational signals page 03 Economic opportunities page 03 Summary page 03 Appendix A page 04

5 01 INCENTIVES AND OPPORTUNITIES SIGNALLED BY TRANSMISSION CHARGES IN SCOTLAND Introduction The purpose of this paper is to consider the principles of electricity transmission charging and to explore how incentives contained in the Ofgem-approved, National Grid charging methodology could benefit large energy users in remote Scottish locations, with potential benefits for economic development of such areas. Nothing in this paper would require a change to legislation, although Clause 5 of the Electricity Act (1989) 1 requires the Secretary of State to make an order granting any exemption from the need to hold a licence to participate in transmission, or any other licensable activity. In addition, any change to transmission charging could only apply to non-domestic users, in view of the common tariff obligation for domestic customers in the North of Scotland 2. Changes would also require agreement of the energy regulator, Ofgem. This paper does not attempt to provide a detailed economic analysis of the financial benefits available from modification of tariff or generator connection arrangements as described. It is intended as a discussion document, to highlight how locational signals contained within National Grid s existing transmission tariff could be improved in a way that increases cost-reflectivity and that could support economic development in remoter areas of Scotland. Principles of network pricing As the provision of electricity transmission infrastructure is effectively a monopoly, revenue is regulated in order to protect the interests of customers. To a significant extent, allowed revenue is based on an allowed rate of return on an agreed regulatory asset value (RAV). Regulatory theory recognises that this approach incentivises unnecessary investment and counters this by scrutinising proposed investment to ensure that it is efficiently undertaken. Licence conditions also require National Grid, the GB Transmission System Operator, to set charges in a way that reflects the cost of infrastructure provision for each type of user at each location on the network (ie costreflective charging 3. This means that, National Grid sets transmission charges based on network topography and the incremental cost of connecting an additional 1MW of load, or generation, at a node 4. One final consideration in relation to network charges is that generators located far from demand will require more network investment to bring their power to where it is needed and the converse is true for demand customers located far from generation. Network tariffs therefore provide locational signals, although this important consideration is often ignored. Locational signals in existing Transmission network use of system (TNUoS) charges Considering only the Wider tariff component of generator TNUoS 5, as shown in figure 1, a comparison of zonal transmission charges for demand and generation, shown in tables 1 and 2 below, clearly shows that demand has a greater incentive to locate in Scotland compared with anywhere else in GB. For every 1 MW of load, a relatively intensive user in the north of Scotland (zone 1), with a load factor of 40%, would save around 6.40/MWh compared Hydro Benefit Replacement Scheme & Common Tariff Obligation. Three-year review of statutory schemes: Government. Response, 4 July onse_hydro_ Benefit_4_July.pdf 3 For a more comprehensive explanation, see Electricity Charging Seminar Level Playing Field, National Grid, 21 July 2016, nationalgrid.com/sites/default/files/documents/ charging%20seminars%20-%20tx%20and%20dx%20charging%20overview%20 session%20v1.0.pdf 4 Note that cost-reflective pricing avoids cross subsidy between different groups of users, so that arguments in favour of reducng charges for generators in the North of Scotland will fail because changes will be perceived as one group of commercial operators being subsidised by another group of commercial operators. 5 Final TNUoS Tariffs for 2018/19, National Grid, January 2018, page 20. General components of generator TNUoS - com/sites/default/files/documents/final%20tnuos%20tariffs%20for% %20-%20report.pdf.

6 02 INCENTIVES AND OPPORTUNITIES SIGNALLED BY TRANSMISSION CHARGES IN SCOTLAND with an identical load located in the Midlands (zone 8) 6. Figure 1: Components of generator TNUoS On the other hand, the cost for a wind (intermittent) generator located in the northernmost part of Scotland (Zone 1), is around 7.60/MWh, compared with a generator connected in Mid Wales and The Midlands (zone 18), or 8.20/MWh 7 in zone 27. The locational signal is therefore that generation should not connect in zone 1, because there is a system constraint that will require investment to facilitate the additional export. The charge for connecting a generator in West Devon and Cornwall is negative, because this zone contains an excess of demand, behind a system constraint, meaning that additional generation would benefit the system in that area. A more visual depiction of GB transmission zones is shown in the map in Appendix A. Table 1: Demand tariffs for halfhourly demand customers by zone 8 Table2: Generation Tariffs by zone 9 6 Difference in demand tariff for connected capacity, zone 8 minus zone 1, is 22,466/MW. A load factor of 40% is 1MW x 8760hrs/annum x 0.4 = 3504MWh. Allocating the 22,466 capacity cost equally across consumption equals 6.41/MWh. 7 These calculations are based on spreading the /MW charge across the output of a wind unit with a 40% load factor (as per the Table 2 tariff), producing around 3.5GWh/annum per MW of capacity. 8 From Table 2, Final TNUoS Tariffs for 2018/19, National Grid, January From Table 7, Final TNUoS Tariffs for 2018/19, National Grid, January 2018.

7 03 INCENTIVES AND OPPORTUNITIES SIGNALLED BY TRANSMISSION CHARGES IN SCOTLAND Responding to locational signals Before further consideration, it should be noted that transmission charging is designed to recover 83% of allowed revenue from demand, as generation charges are limited to an average of 2.50 by EU regulation 10. This explains the apparent anomaly of demand charges being so much higher than those for generation; particularly in the south. Another important point to note is that 11 out of the 27 generation tariff zones are in Scotland (8 of these being in the north of Scotland). If transmission demand tariffs were to be disaggregated to match generation zone boundaries for large industrial customers, then it would be reasonable to expect significantly lower prices for demand in remoter areas of Scotland, in the same way that generators benefit for connecting behind the demand constraint in zone 27. It is therefore likely that disaggregation of transmission demand tariffs could deliver significantly greater savings than are offered by existing Transmission locational pricing signals. In summary and considering only the cost of electricity, it would make sense for demand users with a high energy consumption, to locate as far away from zone 12 (London) as possible and disaggregation of transmission demand charges would maximise the customer benefit from investing in remote locations, where the economic benefit of development would be greatest. In relation to generation, the clear signal from the transmission charging methodology is that generators should seek to meet local load and avoid connecting to the main transmission system. If a suitable load was available, then this could be served by a dedicated local network, which would need either a licence or an exemption. The avoided cost of connection to the traditional system would allow generators to earn more revenue while charging their customers less, which would be a significant advantage for an energy-intensive business. Economic opportunities By adopting an economic development policy, based on responding to the cost-reflective transmission charging regime, the Scottish Government could promote development of energy-intensive, remote area economies, based on renewable generation. A policy based on an existing, efficient pricing regime is also less risky than one that depends on either the introduction, or the long term continuation of, some form of supporting cross-subsidy. Lessons from history are that this approach has been successful in the past, with aluminium smelters at Kinlochleven, Fort William, Invergordon and Foyers (19th century). The history of the only remaining smelter at Fort William, now owned by Liberty Aluminium, shows both the benefit of co-locating renewable generation and demand and the value of renewables in minimising exposure to fluctuating market prices. Examples of energy-intensive application are; Chemical (eg manufacture of renewable ammonia that displaces the use of methane) Industrial (eg aluminium, as exemplified by Icelandic use of renewable electricity) Data centres (a sector being strongly pursued by Ireland) Summary Transmission tariffs in GB are based on a marginal cost methodology that results in strong locational signals. Generation and demand are analysed separately, with the result that Scotland is generally a good location for demand, but increasingly expensive for generation connections; particularly towards the north of the country. If tariff prices are understood to offer locational incentives, then it is rational to seek the maximum disaggregation of demand charges, to highlight areas where maximum benefit to the system means minimum charges for customers. Generators can avoid significant charges if they supply load by direct lines, but may need a licence or an exemption to do so. Energy-intensive users require reliable energy at competitive and stable prices and will provide some good quality employment and local tax revenue, although 10 (EU) No 838/2010 entitled Guidelines for a Common Regulatory Approach to Transmission Charging was introduced to provide a common regulatory approach to transmission charging across all the Member States. This Regulation, in Part B (paragraph 3), restricts the annual average transmission charges paid by electricity generators in Great Britain to the range of 0/MWh to 2.50/MWh. electricity/codes/connection-and-use-system-code/modifications/cmp261- ensuring-tnuos-paid

8 04 INCENTIVES AND OPPORTUNITIES SIGNALLED BY TRANSMISSION CHARGES IN SCOTLAND appropriate development will not overload the social infrastructure of the host area. Common Weal urges the Scottish Government to open discussions with Ofgem, with the aim of promoting increased cost-reflectivity of transmission network pricing in Scotland for large electricity users. Ofgem should also be asked to consult with National Grid on potential levels of demand pricing in, eg, transmission zones 1, 3 and 4. The Scottish Government should also investigate provision of direct networks by the proposed Scottish Energy Company, to link generators with demand and thereby avoid high National Grid charges. Appendix A National Grid Generation zones map Final TNUoS Tariffs for 2018/19, National Grid, January 2018, page 47. General components of generator TNUoS sites/default/files/documents/final%20tnuos%20tariffs%20for% %20-%20report.pdf

9 05 BUILDING SCOTLAND S FUTURE NOW A new approach to financing public investment craig@common.scot 3rd Floor, 111 Union St, Glasgow, G1 3TA

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