Regen's response to Ofgem's RIIO-ED3 framework consultation

Key points from our response are:

• Delivering a long-term programme of upgrades: Regen has long argued that one of the drawbacks of the current regulatory framework is that investment fluctuates cyclically, impeding delivery. The introduction of Regional Energy Strategic Planners provides an opportunity for a longer-term approach to network investment.
• Handling high volumes of LCT connections: Increasing volumes of EV charger and heat pump connections will put customer services under pressure before network capacity runs out. Customers and installers are currently receiving mixed levels of service – this will need to improve.
• Optimal use of distribution network flexibility: Ofgem has captured the nuanced trade-offs of applying flexibility at the distribution network level. Regen would welcome the regulator taking an active role in supporting the development of whole-system cost-benefit analyses so that solutions are deployed to deliver optimal outcomes over the long term.
• Improving transparency and accountability: Accountability will be critical to delivering consumer outcomes in ED3. Ofgem should resume publishing comprehensive comparative DNO reporting via annual reports and ensure that roles, responsibilities and the governance framework are clearly defined when the RESPs are introduced.