Trisha's Blog March 2025

Trisha McAuley OBE, Chair, NGET Independent Stakeholder Group: Reflections on the RIIO-3 Call for Evidence

I am pleased to share insights from our recent response to Ofgem's Call for Evidence regarding NGET's Business Plan for the RIIO-3 period. The RIIO-T3 planning period has taken place against a unique backdrop for the British energy sector and the interdependent combination of the global energy security landscape, the cost-of-living crisis and the imperative to accelerate the path to Net Zero. The UK Government is strongly committed to rapidly advancing Britain’s energy transition, targeting Clean Power by 2030, a key component of which is undertaking significant upgrades to Britain’s electricity transmission infrastructure. This Business Plan is a step change from the asset replacement focus of RIIO-2. It is inevitably more expansive and the infrastructure investment approach, its scale, its focus and its timely delivery are of critical significance to our energy future, and to sustainable economic growth and social value.

NGET’s funding submission requests far higher spend than any previous price control, as well as there being significant differences between the baseline and pipeline positions. Transmission Owner plans must present overall value for money for the end consumers, over the short- and long-term, especially given the ongoing cost-of-living crisis.

The ISG is positive about this ambitious Business Plan which we believe is of high quality. This is as it is very clearly outcomes-focused and because, in general, it sets out, clearly, coherently, consistently and in the right level of detail: why the investment is needed; how it will be delivered and when; the benefits to stakeholders; the risks and tensions; the trade-offs that will have to be made; and the external interdependencies impacting delivery. However, while we believe that this Plan is very good, there is room to get to an even higher standard and our response highlights areas for improvement and further development. 

 It goes without saying that the deliverability challenge is a daunting one, requiring network companies to work in completely different ways, and to do so quickly and with agility. The consequences of non-delivery would be severe for stakeholders and for society. There is clearly ambition in this space, and NGET displays confidence and optimism around plan delivery. Going forward, we expect to receive updates on NGET’s readiness to rise to the deliverability challenge, the risks and uncertainties ahead, and the relevant assumptions underpinning the ongoing delivery of the Business Plan. We want to ensure that NGET understands the risks of non/late delivery that come with the sheer scale of what is to come, and the step change required. 

We believe that one of the most significant aspects of NGET's Business Plan is the emphasis on stakeholder engagement, which we refer to as the "golden thread." We have ISG members with strong expertise and experience in stakeholder engagement and, generally, NGET’s engagement is now, overall, the best of the utility companies we have worked with over the years. They have a systematic, strategic, professional and well thought out approach. We have continued to see improvements on engagement over the last price control, in particular local engagement with the regional approach to the Business Plan. The shift in the last couple of years to greater joint delivery of engagement events is positive – as is planning together with industry and regional partners. While we have flagged some areas for improvement, we have seen broad compliance with our ISG Engagement Principles.

There are a number of areas where we welcome the fact that NGET has showed leadership e.g. working with networks and local authorities to deliver engagement. NGET led the engagement on bill profiling and investment costs to the benefit of all Transmission Owners. The company has been proactive in sharing insight and findings with key stakeholders including Ofgem, Citizens Advice, and other energy companies. We commend NGET for conducting the industry leading research into consumer affordability. It is clear from the narrative, and from our engagement with NGET, that they are actively prioritising their obligations to the paying consumer, rather than attempting to minimise the extent of transmission costs on the whole bill.

However, although the emphasis in the Business Plan on community benefit and engagement, particularly in relation to the Accelerated Strategic Transmission Investment (ASTI) programme, was strengthened in response to ISG challenge but there is much more to do in this critical space. We have received updates on the work that has gone on at community level. We have witnessed NGET shift from a “show and tell” approach, which is not good practice, to hearing about good “bottom up” engagement within and with communities, focusing on their priority and needs. This has largely focused on community benefit, and we would like to see much more evidence, and a much stronger, improved approach to transparency with affected communities on investment optioneering and rationale for trade-offs, choices and decisions.  The challenge will be to apply its good practice engagement consistently to all areas to better understand local priorities.

The RIIO-3 Business Plan represents a significant step forward for NGET, but it is essential that we continue to challenge and scrutinise its implementation. The ISG remains committed to holding NGET accountable and ensuring that stakeholder interests are at the forefront of decision-making. We look forward to seeing how NGET addresses the challenges and opportunities that lie ahead, particularly in fostering a collaborative approach with all stakeholders involved.

In the meantime, please do read out response in full where we go into detail on areas of strength and areas for improvement across topics including regional engagement, ASTI, asset maintenance, network resilience, supply chain and workforce, connections, the environment and nature, responsible business, innovation, and IT, digital and data.  

In closing, I would like to express my gratitude to all ISG members for their dedication and expertise throughout this process. Together, we will continue to work and to challenge to ensure that NGET's Business Plan not only meets the needs of consumers and communities but also contributes to a sustainable energy future for the UK.

You can read our RIIO-T3 call for evidence response here.