National Grid Electricity System Operator ('NGESO') has worked to introduce a new balancing service (Winter Contingency Service ('WCS')) to help manage the system during winter 2022/23. In line with the requirements of their C16 licence condition, ESO previously ran a consultation from 8 August 2022 to 5 September 2022, seeking industry views on proposals to modify their C16 licence documents to reflect how the product would be procured and used.
Following the consultation, NGESO submitted a report to us on their proposed changes. They were unable to provide a consolidated set of proposed changes at that stage. NGESO have indicated that they are now ready with proposed changes for WCS. Given the pressing nature of having a clear methodology that avoids potential issues in cash-out, ESO requested us to provide them a direction not to consult.
This letter sets out our decision on that request. We have determined that it is not suitable to have no consultation on these changes, given the broad and potentially large industry impacts. Under the C16 licence condition, NGESO are required to consult 'for a period not less than 28 days'. However, we recognise that NGESO has consulted on aspects of these changes previously and there is an urgency around getting a correct process in place. Therefore, this decision letter provides the ESO a direction to deviate from the minimum 28 day period for consultation, instead allowing a period of at least 7 days for this consultation. Additionally, reflecting the urgent nature of implementing these changes, the 7 days set out in the C16 licence condition allowed for the ESO to prepare their final report to us is reduced to 4 days by this decision.