Regen has responded to Ofgem's consultation on its ED3 sector-specific methodology, welcoming the move towards longer-term, strategic planning for distribution networks. We have long called for investment ahead of need, so we strongly support Ofgem’s shift towards a more proactive approach.
Regen has worked extensively with distribution network operators to pioneer and deliver Distribution Future Energy Scenarios (DFES) analysis since 2015. This experience has provided us with valuable insights into key considerations for the ED3 price control period across the Regional Energy Strategic Plan (RESP) and DFES processes.
ED3 should give DNOs the flexibility and tools they need to invest ahead of need, support electrification and enable timely grid connections. To achieve this, we believe that DNOs should draw on a wider range of evidence than the transitional RESP alone. Granular, spatially rich data, such as that provided by DFES, can help networks stay ahead of local demand and avoid missed investment opportunities.
Our response calls for incentivising DNOs to offer earlier and lower-cost connections, publish better performance data and improve the customer experience. Faster, smarter connections will be essential as demand for heat pumps, EV chargers and rooftop solar grows. We also emphasise the importance of planning for colder-than-average winters, incorporating realistic assumptions about peak demand.
A coherent approach to electrification of heat is also needed. Heat electrification and energy efficiency will shape network demand more than any other part of the transition, so ED3 needs a clear framework to support delivery. We argue that DNOs should have a defined role in helping identify network impacts, opportunities and areas with available headroom.
We support Ofgem’s plans to strengthen Innovation Strategies and introduce a deployment fund so that proven solutions can be scaled. However, we also emphasise the need to open up the Strategic Innovation Fund to third-party innovators, ensuring that ideas with wider social or environmental value can progress, even if the network benefit is limited.
Finally, flexibility will play an important role in managing constraints during ED3, but networks need certainty about its role. We recommend that Ofgem clarifies how flexibility should be used and signal any future changes to the framework so DNOs can plan with confidence.
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