Will Ofgem’s Targeted Charging Review bring an end to Triads?

Ofgem has launched a consultation into how the costs of transporting electricity to homes, public organisations, and businesses are recovered. Proposed changes could remove the incentive for Triad avoidance.

Costs for transporting electricity are currently recouped through two types of charges:

• Forward-looking charges, which send signals to how costs will change with network usage
• Residual charges, which recover the remainder of the costs

In order to ensure that these costs are shared fairly amongst all users of the electricity network, Ofgem are undertaking a review of the residual network charges, as well as some of the remaining Embedded Benefits, through the Targeted Charging Review (TCR).

Proposed options for residual charges

On setting transmission and distribution residual charges, Ofgem has conducted an analysis of different approaches, leading them to two primary options that they are consulting on, the first of which is a ‘Fixed Charge’. This is highlighted as Ofgem’s preferred option, in which charges would be set for individuals in customer segments, with these segments being based on an existing industry approach.

The second option is an ‘Agreed Capacity Charge’. This would see a charge calculated directly for larger users who have a specific agreed capacity. Capacity for smaller households and businesses would be based upon assumed levels.

Ofgem’s assessment is that a reform of residual charges would result in potential net system benefits up to 2040 between £0.8bn and £3.2bn, with benefits to consumers as a whole in the range of £0.5bn to £1.6bn. In addition to this, Ofgem assess that the proposed changes would save around £2 a year for households in the longer term.

Either scenario would see a fixed rate for Transmission Network Use of System (TNUoS) charges. However, under the Agreed Capacity Charge option, as charges would be based on capacity, there would potentially be some room to reduce contribution to the residual charges.

Changes to Embedded Benefits

There are a some notable points within the TCR regarding Embedded Benefits; notably, Ofgem are consulting on setting the Transmission Generation Residual to zero, subject to maintaining compliance with the current cap on overall transmission charges to generators. This will remove a benefit to larger generators that receive a credit from these charges at present.

Another key point is that Ofgem are exploring the removal of the Embedded Benefit relating to charging suppliers for balancing services on the basis of gross demand at the relevant grid supply point. This is important as it would eliminate the incentive of Triad avoidance. Currently, National Grid identifies three Triads each year in order to calculate the TNUoS charges an organisation will incur. Such transmission costs can be reduced if demand is decreased when a Triad Alert is called (a warning that demand will be high that day). Find out more about what Triads are and how you can avoid them here.

For both of these points, Ofgem believes that whilst these benefits reduce costs for individual companies or consumers, they don’t reduce the total network costs that users need to fund collectively. This can lead to greater costs for other users and, if not addressed, Ofgem say this will lead to less efficient outcomes that are not in the best interests of consumers as a whole.

BSUoS changes

The Review outlines a proposal for Ofgem to set up a Balancing Services Use of System (BSUoS) task force. The task force would be responsible for considering how cost-reflective and effective the current charges within BSUoS are. From this, they would evaluate the potential to provide a better system in the future, looking to make it more cost-effective. This would come with the responsibility of assessing how feasible any improvements to BSUoS charges are.

Ofgem are deliberating between two reform options; a partial or a full reform of BSUoS. A partial reform would see a reduction in suppliers’ contributions to BSUoS charges, while a full reform would see the removal of BSUoS payments, and require smaller embedded generators to pay BSUoS charges.

Under the current system, suppliers are charged BSUoS based on net demand. A bill is calculated on gross demand and then any embedded generation reduces this cost to the supplier, which is recouped from consumers via a separate non-commodity cost (NCC) charge. Under the proposed full reform, embedded generators would be considered the same as transmission connected generators, leading them to be charged for BSUoS with no savings.

The impact to Triads

Triads are currently evaluated based on average demand during the three highest half-hourly peaks of electricity use between November and February. These periods can be forecast, allowing network users who employ Triad avoidance to reduce their electricity consumption in anticipation, for example by instead using on-site generation, Demand Side Response (DSR), or storage. Ofgem argue that whilst this reduces their own costs, the total network cost doesn’t change, meaning that those unable to employ the same avoidance methods pay a larger cost.

Under the proposals by Ofgem, charges will remain roughly the same to users where no Triad management is in place. However, it is expected that large increases will occur for those who use Triad avoidance to reduce the impact.

The new system would see single fixed charges applied based on voltage level. Ofgem believe this will result in reductions in charges for larger SMEs, whilst SMEs at the lower end of consumption will see moderate increases. Importantly, users with on-site generation will pay the same charge as those without, in contrast to the current arrangements.

The Triad period this winter will be unaffected, as will winter 2019 going by Ofgem’s timetable. However, this will have a significant impact on how businesses may seek to recover operating costs in the future. No replacement could see a lack of incentive for DSR, resulting in adverse constraints on the market.

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