Download | E3G Response To The UK Government's Consultation.pdf

E3G, an independent climate change think tank, submitted a response to the UK Government's consultation on the Future System Operator draft licenses. They believe the draft ESO license captures the policy intent, but it is sometimes difficult to understand the underlying reasoning for specific license conditions. E3G suggests the Government should explicitly outline how it pictures the new FSO operating and why it made certain decisions in the license conditions.

For the draft GSP license, E3G had no comment. However, they support the creation of the ISOP and the approach taken to creating its license. They suggest considering specific skills or areas of expertise for the FSO board, such as industry expertise, consumer representation, or climate change knowledge.

E3G also recommends clarifying how the Energy Strategy and Policy Statement interacts with other license conditions, ensuring transparency, and outlining the requirements for the ISOP to make long-term development scenarios. They support the need for improved risk and resilience planning, transparency, and explaining how longer-term scenarios affect shorter-term planning.

Additionally, E3G believes it would be valuable to see increased clarity on the transition to ISOP, including a timeline and list of actions, and to outline the redress processes for non-compliance, stakeholder concerns, and performance assessment. They also suggest considering the processes for resolving disagreements between Ofgem/Government and the ISOP.