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Proposals for a Future System Operator Role (2021)

The IET welcomes the opportunity to comment on an open consultation by the Department of Business, Energy and Industrial Strategy (BEIS) and Ofgem on Proposals for a Future System Operator Role.

We would like to draw particular attention to the following issues within our response: The FSO’s Remit, Urgency, Organisational Design, Ownership, Leadership & Culture, Relationships & Coordination, and Authority & Responsibilities

We believe there is genuine urgency to establish the FSO so that it can positively impact the strategic aspects of delivering Net-Zero.

We are concerned that the likely timescale for legislation will cause harmful delays. The FSO will bring new value only once it extends the current ESO’s remit to include more effective strategic planning, management, and greater technical and market coordination across the energy system.  

It would be highly desirable to get started early in a shadow mode, but for this to be more than simply a re-branding of the current ESO.  

IET Recommends:

The proposed FSO has the potential to be a highly effective element in Britain’s energy transition if we consider the following (more details in our response)

  1. True whole-system capability
  2. Early enablement by BEIS and Ofgem
  3. The FSO organisation requires a clean-sheet design to ensure management focus on the diverse areas of critical real-time system operation
  4. The ownership of the FSO should guarantee absolute impartiality in its operation and a focus on best value engineering/market outcomes.
  5. The complex relationships with other actors must be set on a path that is crystal clear, with a particular emphasis in the near term on the integration of ESO and DSO functions.
  6. In tandem with the Energy Code Reform consultation, it is an imperative that agile governance and change processes are established