Contact Details. For any enquiries related to this document, please contact: Katie McArdle, Grid Connections Manager

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2 About Lightsource Lightsource Renewable Energy Holdings Limited (Lightsource) is a company incorporated in England and Wales and is currently the leading solar photovoltaic (PV) energy generator in the UK and Europe, with a quickly growing office in Dublin, Ireland, and one of the top ten largest solar PV energy generators globally. Solar PV is set to deliver the best value for money among all energy sources even fossil fuels. By 2025 it is predicted to be the cheapest energy source globally, and by 2050 it is expected to be the largest energy source globally. Beyond using proven, affordable and best quality solar PV technology to meet the UK s rising renewable energy demand, Lightsource is contributing to the EU s efforts to reduce its carbon footprint. Community engagement and respect for the natural environment are the cornerstones of Lightsource operations from project inception to project completion. Since its establishment 5 years ago Lightsource has been a key player in the ground-mounted solar PV market. Beyond ground-mounted installations, Lightsource has also developed a commercial and domestic rooftop division, which has so far assisted a large number of organisations and in reducing their operational costs by halving their electricity bills and increasing their competitiveness in the UK market. By installing domestic solar PV installations on rooftops Lightsource helps in bringing down the electricity bills for home owners and empowers individuals to contribute to solving the world s climate change issues. 1

3 Contact Details For any enquiries related to this document, please contact: Katie McArdle, Grid Connections Manager Lightsource, 7th Floor, 33 Holborn, London, EC1N 2HT +44 (0) Contents About Lightsource... 1 Contact Details Introduction Response to Consultation Questions Enduring Connection Policy Objective and Underlying Principles Enduring Connection Policy: High level approach Renewable Targets Interconnection, Demand and Generation Forecasts Treatment of Non-GPA Applications I-SEM Design DS Network Issues Demand Community Based Schemes Planning and Consenting Considerations Conclusions Proposed Transitional Arrangements

4 1. Introduction Lightsource welcomes the opportunity to respond to the Commission of Energy Regulation (CER) Review of Connection and Grid Access Policy: Initial Thinking & Proposed Transitional Arrangements (Consultation) dated 11 December 2015, to submit views and information regarding the development of an enduring grid connection and access policy. It is our intention to demonstrate to the CER that implementing an enduring policy will provide the necessary confidence to solar PV investors and developers in Ireland. This paper will outline the Lightsource views on the following areas: Facilitate the mix of generation, technology, and provision of system services required for a safe and secure operation of the system; Prioritise projects which make the most efficient use of the existing network; Encourage large demand connections to make efficient use of the existing network; Include planning permission as a criteria for offer issuance; and Include projects currently processed under the non-gpa process in the GPA process. 2. Response to Consultation Questions 2.1 Enduring Connection Policy Objective and Underlying Principles Do you agree with the policy objective for the Enduring Connection Policy? Are there other matters the CER should consider? We agree the policy objective for the Enduring Connection Policy should be fair opportunity for generation to receive offers of connection to the network taking account of system needs, efficiency, national policy and the consumer interest. We suggest that European Policy should also be taken into account given the European Commission 2030 Climate and Energy Goal Policy Framework has not yet been translated in national policy. National 2030 policy will require further penetration of low carbon and renewable generation which should be considered when designing the Enduring Connection Policy. We also believe that lowering connection costs for customers should be a central policy objective. We believe that there are huge costs savings available for new connections if a fresh engineering approach can be taken with some aspects of network design. In particular, for new solar projects simple solutions such as modular substation designs and facilitation of more tee connections onto existing lines could lead to significant cost savings that in turn can be passed onto the customer. As a developer working in UK jurisdictions we have experienced this and it appears there are many over engineered and high cost aspects to Irish connection design. 3

5 Do you agree with the application of the above underlying principles to the development of Enduring Connection Policy? Are there any other principles that the CER should consider? We agree with the application of the proposed underlying principles. We suggest predictability should be added as an underlying principle of the Enduring Connection Policy. As a result of policy favouring viable projects, projects shall be required to commit development funding prior to receiving a connection offer. Connection policy needs to be predictable to provide a business case for such development investment in advance of receiving a connection offer. Predictability can be achieved if DSO and TSO s: 1. Increase Customer Engagement: Engagement with customers before the application process allows customers to collate gird intelligence and make informed project decisions. This benefits both sides as speculative applications are reduced and viable projects are progressed. Therefore time and resources on both sides are not wasted on projects that will never materialise. In England the DNO s publish and update Heat Maps to enable customers to assess the available capacity. Additionally, they regularly host customer workshops / meetings where developers can discuss their pipeline of projects and get high-level feedback from network planners. Subsequent to these workshops applications are withdrawn or progressed, hence decreasing significantly the amount of applications that enter the offer process: Northern Powergrid - SPEN - UKPN - (Registration needed) ENW - SSE - WPD - https :// Map/Distributed-generation-EHV-constraint-maps.aspx 4 As an example, a quick win would be fortnightly or monthly updates to the Offer Process Application Information (Excludes Accepted offers and Contracts under modification) which is published on the EirGrid website, along with an indication of the 110 kv nodes the applications relate to. This would have a low resource impact on the TSO s and DSO s as they already have the information, but would be greatly beneficial to both customers and the

6 DSO/TSO as it would reduce speculative applications as customers would be able to assess the opportunity for capacity and the queue duration. Predictability as an objective is further supported by the Transparency objective already introduced in the consultation. The more network data the TSO/DSO publish, enables customers to make informed decisions about development. Hence reduces speculative applications and focuses TSO/DSO resources on viable projects. 2. Guaranteed Standards of Performance The offer process should be bound by guaranteed standards of performance or service level agreements. Having fixed timelines for the offer process and acceptance period allows customers to plan appropriately for their projects; an open ended process adds uncertainty to financial investors. Conversely, connection offer longstop dates should be enforced when customers do not meet project milestones which would prevent customers hoarding capacity. TSO s and DSO s should be resourced sufficiently to meet the guaranteed standards of performance. The DSO has received a significant increased number of applications over the past year (over 350 in 2015 versus an average of 30 per year previously) and now needs to be resourced adequately to meet this increased demand. All of these applicants have paid and contracted with Eirgrid / ESB in the expectation of receiving grid applications with the defined 90 day period Enduring Connection Policy: High level approach What is your view on the high level processing approach outlined above? Are there other processing approaches the CER should consider? We agree that the high level processing approach outlined is reasonable and appropriate. A Group Processing Approach is justified given the volume of generators likely to seek connection under the new regime. Group Processing will result in more efficient network development, lower average cost of connections and facilitate the sharing of upgrade costs between multiple generators. We agree that smaller and more frequent rounds of capacity should be allocated to projects which meet the qualification criteria. We suggest that annual gates are run for qualifying projects which would balance the requirements for qualifying projects wishing to proceed with the administrative burden of processing the gates. Opening the gate for a relatively short period of time, for example 1 month, would allow the System Operators to process the gate, issue connection offers and have these offers accepted or declined before the processing of the next gate 1 year later. Projects which do not achieve the qualification criteria in time for this application month in any given year would have a maximum delay of 1 year before the application month for the following year. The timing of these gates would need to correlate with the financial support policies, to ensure development is supported as opposed to hindered.

7 Much of the difficulties for Gate 3 generators stemmed from the lack of qualification criteria for the projects. Shared network assets lead to interdependencies in the timelines of subgroup projects which were frequently at different stages of development. Application of suitable qualification criteria, such as planning consent, would ensure projects within the Gate are at the same stage of development which would minimise such issues whilst capturing the benefits of group processing. The expectation that the 2020 RES-E 40% target can be achieved by Gate 3 should be tempered by the risks that remain in achieving this target, the potential for electricity demand growth and the projected shortfall in the RES-H and RES-T targets. Surplus capability within the RES-E sector should be utilised to address any potential shortfall in the overall 2020 energy target. We also recommend interactivity which is an offer process approach established in the UK. It allows DNO s to process multiple applicants at once where they are aiming to connect at the same point on the network. This allows multiple offers to be made at once and the applicant highest in the queue who accepts the offer will be allocated the capacity. Where an offer is issued and then becomes interactive as an application for the same point of connection is made, the normal acceptance period is reduced to 10 days, for example. If the customer fails to accept the offer in the reduced timeframe the offer is granted to the next applicant in the queue. There are varying interactivity processes in the UK, examples from Western Power Distribution and Northern Powergrid are attached. Lessons learnt from the UK DNO s in this area may significantly reduce queue length, reduce design work and remove speculative applications from the existing or future queues. 2.3 Renewable Targets Do respondents agree that the CER should consider the connection of renewables as one of several drivers to be balanced in the development of an enduring connection policy? Whilst it is reasonable to consider several policy drivers, the connection of renewables should be the primary driver. Given the clear policy direction in the European Commission s 2030 Climate and Energy Goals Policy Framework and 2050 Energy Roadmap, grid access for renewable and low carbon generation will be essential in achieving future targets. Failure to prioritise this clear policy need in an enduring steady state grid access policy would be ill conceived and shortsighted. 2.4 Interconnection, Demand and Generation Forecasts Should connection policy make explicit provision for interconnectors? If so, what issues should the CER take into consideration? 6

8 Connection Policy should make explicit provision for interconnectors to provide clarity for all market participants. Future interconnection should be designed to facilitate increased levels of renewable penetration, achieve energy policy goals and should not undermine any market based renewable support schemes. 2.5 Treatment of Non-GPA Applications Should the technologies and projects currently covered under the non-gpa process be processed under the GPA process when the new connection policy is implemented? All technologies and projects currently covered under the non-gpa process should be processed under the GPA process when the new connection policy is implemented, provided they are above a minimum capacity threshold of 1MW and meet the application criteria for the enduring connection process. Should some categories of project be processed outside the GPA process when the new connection policy is implemented? Microgeneration is currently outside of the non-gpa and GPA processes and should remain outside these processes. Lightsource recommend that the limits for microgeneration are increased from current limits in the context of the upcoming Network Code - Requirements for Generators. The non-gpa process was established to facilitate the connection of small renewable and low carbon generation which fulfilled the public interest criteria. This process was required to provide connection access to such projects due to the Gate 3 process at the time. If the GPA process provides regular gates for projects which meet certain criteria, the raison d etre for the non-gpa process is largely removed. All technologies and projects may participate in the GPA process (subject to application criteria) which will determine interactions between generators and ensure optimal system development. The non-gpa process should only be retained for projects below a fixed threshold (ISEA and Lightsource recommend 1MW) to simplify the process for small generators with all generators above this threshold being processed through the GPA process. The non-gpa process should apply the same qualification criteria as the GPA process to ensure equity in the processing of such generators. It is essential that the non-gpa process continues to operate as it does at present until the GPA process is available for a number of reasons: 7 The projects which apply under the non-gpa process do not have an alternative connection process available and must meet the criteria established in CER/09/099. The Non-GPA process is current policy and until the enduring process is in place it would create a moratorium to such non-gpa applications if it was prematurely stopped. A previous introduction of a moratorium on renewable connections had a very significant detrimental impact on the industry in Ireland and should be avoided at all costs. Grid access is essential to the non-wind renewable technologies seeking to establish a presence in Ireland. Taking away grid access whilst designing the enduring access

9 regime would retard the development of such technologies in Ireland and create significant investment uncertainty. This would be contrary to national energy policy and the purpose of the enduring access regime. For example Solar is a proven technology internationally and access policy should not hinder technology innovation. Solar generation can be deployed significantly faster than other technologies due to construction timelines and less planning and social acceptability challenges. Additionally, it is less geographically restrictive so it can be placed in close proximity to the existing grid and negate the need for costly grid development. Non-wind renewable and low carbon technologies complement the existing fleet of wind energy in Ireland and make efficient use of energy infrastructure. Such projects should be encouraged rather than disadvantaged by regulatory uncertainty. The volume of offers being issued under the non-gpa process is quite modest relative to the scale of contracted wind and will grow relatively slowly given the nature of non GPA offer processing (i.e. sequential processing of the applications on a nodal basis). There are very significant volumes of contracted wind projects which will continue to be constructed in the coming years. Other technologies do not have such a pipeline of projects and would be disproportionally disadvantaged should the non-gpa process be terminated prior to the GPA process being established. Many generators have applied in this process and have a legitimate expectation of receiving a connection offer under this process. This should not be removed until an alternative process is available. On its current trajectory the enduring process, when fully consulted on and designed, is not likely to allow issue of connections offers until mid-2018 at best. Allowing for development and construction of connection infrastructure, energisation will be post 2020 for even the simplest connection methods. These projects will not connect in time to contribute to the 2020 renewable targets. As stated earlier, there is still uncertainty on Ireland s ability to meet the overall 2020 RES targets and connect any projects which receive offers through the non-gpa process which would otherwise have contributed to these targets. We recommend adapting the non-gpa process in order to prioritise the processing of projects with planning consent whilst the enduring connection process is being considered, thus moving it towards the likely design of the enduring process. This could readily be facilitated by selecting projects according to planning consent date rather than application date when processing non-gpa projects on a nodal basis. 2.6 I-SEM Design Do respondents agree that the CER should progress the development of the Enduring Connection Policy in advance of I-SEM go-live? 8

10 Yes, the CER should progress the development of the Enduring Connection Policy in advance of I-SEM go-live. Given that there are no direct interactions between connection policy and I-SEM it would be wholly inappropriate to delay the development of the enduring connection policy. Furthermore, connection policy may be amended in future should any unforeseen issues arrive that require a specific resolution. 2.7 DS3 Should connection policy facilitate a mix of generation and in particular facilitate providers of system services? Should connection policy focus on certain technology types or rely entirely on market signals? Connection policy should facilitate a mix of generation provided this does not undermine future renewable policy targets. There is also different forms of renewable and low carbon generation so a mix of generation can be achieved without needing to undermine renewable targets. Providers of system services should be facilitated where such services facilitate renewable targets and policy should rely on market signals rather than being prescriptive on technology. Connection policy should also into take consideration of the balancing effect of complementary technologies when reviewing connection capacity on the network. This would ensure optimal efficiency and use of the existing network, lowering cost of network development. For example solar PV is highly complementary to wind in generation cycle (for example with more wind traditionally generated at night versus solar peak generation during the day). 2.8 Network Issues Should projects which make the most efficient use of the existing network be prioritised over projects driving more deep reinforcements? Yes, in principle projects which make the most efficient use of the existing network should be prioritised over projects driving deep reinforcements. As outlined above, Solar has the additional benefit of its ability to locate next to the grid and not drive costly deep reinforcements. Additionally, colocation of Solar with existing generation should be supported in access policy, especially in the instances where negligible or minor shallow works or deep reinforcements are required. This would be an efficient use and optimisation of the existing network given the low capacity factors or renewable technology and minimal crossover between generation profiles. The complementary generation profile of solar energy relative to the existing wind fleet confers unique network advantages onto solar energy. We recommend that the benefits of integrating large scale solar onto the existing network infrastructure are accurately determined by the System Operators so such benefits can inform the regulatory decision making and additional deep infrastructure is minimised. It is important that the enduring connection process is introduced in a timely manner and the time impact of complex analysis needs to be established. The practicality of such analysis also needs to be considered as it would need to consider the production profiles of different generating technologies when completing network planning. Different technologies may receive different signals in the same geographical region. Network analysis needs to take into account the 9

11 profile of solar generation. This may require the GPA process to stream projects according to technology which may require minimum and maximum allocations for technology types. The capacity available in different areas will change over time (for example a large demand connection, completion of upgrades, implementation of smart grid technology such active line monitoring & dynamic line ratings) so the analysis may need to be updated for each iteration of the GPA. This may not be practical if an annual process is being considered. We also urge the CER policy to support the development of small private/localised connections from localised generators directly to end users. The benefits of this approach would be as follows: Allow for large users to contract directly with localised generators. Decrease the requirement and necessity for main DSO/TSO reinforcement works which can and are facing large levels of objections inhibiting renewables and network development. Increase competition and supply options for large and medium energy users thereby decreasing energy supply prices to end users. Facilitate the move to smart and more decentralised electricity supply system, where generation is located closer to end users. Facilitate local community developed and used generation. Section 10 of S.I [4] (this amends Section 14 of the Electricity Regulation Act 1999 [2]) is the legislation relating to such direct lines or private wire connection. Currently there is an allowance for a single Distribution System Operator in Ireland however the CER also has an influence on the feasibility of such connections under S.I [4] states that the Commission may grant or refuse to grant to any person a licence to discharge the functions of the distribution / transmission system operator [that licence] shall only begranted to the Board or a subsidiary of the Board. We would request the CER to consider this in terms of enabling small private/ localised connections. Private wire connections are feasible across multiple sites in Northern Ireland by applying for a Generation Licence. In Great Britain, Lightsource has developed Solar Farms by means of private wire connections. The requirements for such connections are planning approval and/ or local authority approval. They are bound by the DNO s requirements in the Connection Agreement at the point of connection. The Developer is responsible for the on-going maintenance and adherence to the terms of the Connection Agreement. Lightsource have already developed private wire / direct supply contracts with large energy users by directly connecting localised generation capacity on private developed networks with 10

12 end users. Indeed an example of such is the Solar Farm underdevelopment at Crookedstone road with Belfast International Airport. Developers need to be informed by TSO and DSO now as to the requirements of such connections in practical terms under the current legislation whilst policy is advanced. Clarity on the definitions of single premises and allowable connection distances from the medium energy user would be helpful in the short to medium term. We believe this approach meets with the CER policy objectives of meeting DS3 targets, increasing direct supply competition and reducing end user costs. It would also give direct transparency and visibility of use between local generation in a community and a local community based end user. We believe this would help engender greater community support for localised renewable generation in their community. 2.9 Demand Should large demand connection which make the most efficient use of the existing network be encouraged through the Enduring Connection Policy? Yes, large demand connections which make the most efficient use of existing network should be encouraged but should not delay the design of the connection policy for generation connections or frequency of the rounds of offers. The impact of generation and demand on system design are sufficiently different so probably require separate connection processes Community Based Schemes Are there any specific issues the CER should take into consideration regarding community based schemes? As per the ISEA response we would encourage community participation in energy projects and believe community based solar energy schemes should be facilitated as much as possible. The characteristics of solar energy enable microgeneration, auto-production and community solar schemes in a way other renewable technologies cannot. Experience from other markets has shown that widespread community engagement in solar energy is possible if the correct regulatory and market supports are put in place. We believe this is consistent with the aims of the Energy White Paper and should be incorporated into the enduring grid access regime. Consideration could be given to reserving a portion of available grid capacity for local community based schemes Planning and Consenting Considerations Should the CER include planning permission in the criteria for receiving a connection offer? Planning permission for the generation plant should be a requirement in order to be processed in the GPA, rather than receiving a connection offer for the following reasons: 11

13 The previous Gate process favoured speculative applications and there is approximately 25 GW of generation applications seeking connection to what is essentially a 5GW system. It is neither practical nor efficient for the System Operators to perform the necessary technical & commercial work to issue connection offers to generation plant which has a low likelihood of being delivered. Grid capacity is a scarce resource and should be allocated to projects which are likely to be delivered. Planning consent is a key project risk and is public domain information and therefore is an appropriate criterion for being processed for a connection. The determination of whether a project has planning consent is reasonably straightforward and is completed by DCENR when assessing REFIT applications. There is no reason the System Operators or CER cannot fulfil this task if it is a desirable part of connection policy. Planning Consents / notifications could be included with the grid application. The enduring connection policy is being designed to cater for all generation seeking to connect to the system. The O Grianna court ruling impacts upon a subset of these generators and should not determine connection policy for all generators. If this subset of generation requires additional information in order to seek planning consent a separate process for this should be established, for example the provision of feasibility studies by system operators. Consideration may be given to prioritising projects with planning consent in the current non-gpa process where there are several generators awaiting processing. This would be consistent with aims of the enduring process and ensure connection offers are issued to projects with the most likelihood of being realised. Significant development funding will be required if the generation plant requires planning consent prior to its connection application being processed. In order to justify this early investment, it is essential that the connection process is fit for purpose. It should be transparent, predictable, and efficient and provide connection offers in a timely manner. It is incumbent on the CER and the System Operators to ensure sufficient resources are put in place to perform this function. This includes the regular publication of system information so as developers can assess system capacity and other appropriate information and data before the committing the funding required for planning consent. As outlined in 3.1 above, if a higher bar is to be set for making applications and receiving grid offers a corresponding higher standard of interaction with the system operators must be available to developers. Greater detail on potential connection methods, connection costs and development risks will be required. This new level of interaction must form part of this ongoing consultation process. 1) Increase Customer Engagement 2) Guaranteed Standards of Performance 12

14 Are a necessity to enable customers to assess project risk where they are spending ahead of receiving offers. Again system operators should be resourced adequately to do this Conclusions Have we identified the correct policy issues? Are there policy issues which we have not accounted for? The shortfall in the 2020 RES-H and RES-T targets, and the future policy direction of European Commission s 2030 Climate and Energy Goals Policy Framework and 2050 Energy Roadmap are notable omissions from the policy issues identified. Given that grid access is a fundamental requirement of renewable energy deployment, these policy issues should be fully accounted for in the design of an enduring grid access regime. Should the GPA process be retained? And should there be more frequent rounds of offer processing? The GPA process should be retained as identified above with annual gates for projects above a 1MW threshold which have planning consent for the generation asset. Should the non-gpa approach be revised? The non-gpa process should be revised as outlined above for generators above the microgeneration levels but below the 1MW threshold. It is essential the current non-gpa process continues to operate until the GPA process is fully in place. Additionally Interactivity should be considered in efforts to decrease queue length at nodes Proposed Transitional Arrangements Comments are requested on the above proposed transitional arrangements, specifically: 13

15 Whether these transitional measures should be implemented ahead of the development and implementation of the Enduring Connection Policy; Yes the proposed transitional arrangements should be implemented ahead of the Enduring Connection Policy. In the Non-GPA process projects that gain planning consent should be given priority in the queue as this is a demonstration of the viability of a project. Also a form of interactivity could be used to reduce the queue length, as opposed to the current consecutive methodology. The proposed release of existing capacity (policy measure 1) is a sensible suggestion which is beneficial to all stakeholders and should be facilitated. The refunding of stage 1 payments is supported and Connection Offer longstop dates should be enforced. The proposed granting of additional capacity to existing connections (policy measure 2) is misguided and should not be progressed for the following reasons: The proposal breaches the key policy objective of providing a fair opportunity for generation to receive connection offers. It is selecting a group of existing firm generators and granting them additional scarce resource without the opportunity for other generators to participate. This is not in line with the objective of facilitation of a mix of generation and technology. Solar is an emerging technology in Ireland and should be supported by enabling colocation with existing and new wind farms or other generators. The MEC of a connection agreement will not be affected therefore there are no adverse impacts to the network or disadvantage to other customers. This would be a fairer way of optimising the existing network in the circumstances where no shallow works or deeps are required as the MEC of the customer is not altered, but optimised. The consultation recognises that there is no security of supply concern so the granting of additional capacity to existing conventional generation has no reasoned basis. The suggestion that this proposal is an efficient use of the existing network is misguided. Efficient use of the network should be facilitated by encouraging access to projects which meet DS3 criteria, not increasing levels of existing generation characteristics. The Commission recognises that there would be an impact on other generators seeking to connect to the system and therefore the additional generation would be limited to 10% of the current firm capacity of existing units. What analysis has been carried out to determine the quantum of generation capacity to be allocated under this scheme and a cost benefit analysis against allocating this capacity to DS3 projects should be completed. As we move towards smarter grid technologies the CER should allow for newer renewable generators to connect directly to end users creating smaller micro grids. This would have significant network, community and end user benefits. 14

16 It may not be practicable for the System Operators to complete a study and determine the available non-firm capacity without completing an ITC re-run. The timing of such arrangements (30 th June 2016 for policy measure (1) and (2)); The timing of 30th June 2016 for policy measure 1 is considered appropriate. Policy measure 2 should not proceed. The appropriate level of increase in capacity under policy measure (2) to deliver most final customer benefit. It would be wholly inappropriate to increase any capacity under policy measure 2 without completing a cost benefit analysis against allocating this capacity to DS3 participants. 15

17 09/12/2014 New Interactivity Process The process described below is intended to supplement and refine the existing WPD Interactive Connection Applications process, set out in our charging methodologies. Its aim is to improve the process, provide detail on dealing with complex queues and remove the need to extend the acceptance moratorium period where subsequent offers are made to further applicants. The process is set out as an amendment to the wording in the charging methodologies: Interactive Connection Applications The Basic Process 1. There are occasions where we receive two or more applications for connection which make use of the same part of the Distribution System. These may become Interactive Connection Applications, resulting in additional costs. We follow a strict process to ensure fairness and this process is detailed below. 2. The process for managing two or more Interactive Connection Applications will be as described below. The following definitions are used in this Section.

18 09/12/2014 Affected Parties Alternative Connection Offer Application Date Business Day Committed Network Confirmation of Non- Interactivity Connection Offer Customer Distribution System Existing Network Interactive Connection Applications Interactive Connection Offers Interactive Queue Legacy Date all Customers whose Connection Offer(s)/ POC Offer(s) have been identified by us as being interactive. A non-conventional smart Connection Offer involving one or more constraints to avoid the need for network reinforcement. the date upon which we receive all the information (see [2.7] [of the connection charging methodology].) we require in respect of an application. means any day other than a Saturday, a Sunday, Christmas Day, Good Friday or a day which is a bank holiday within the meaning of the Banking and Financial Dealings Act 1971 and will be from 9:00am to 5:00pm (GMT or BST as applicable). means assets that are not yet installed and commissioned on our Distribution System, but which are planned to be so as a result of other Connection Offer(s)/ POC Offer(s) which have been made by us and accepted by other applicant(s). a notice issued by us informing a Customer that their Connection Offer is not interactive. is as described in [1.13] [of the connection charging methodology]. as defined in Section 8 Glossary of Terms. as defined in Section 8 Glossary of Terms. means our currently installed and commissioned Distribution System. arise where we receive two or more applications for connection which make use of the same part of the Existing Network or Committed Network or otherwise have a material operational effect on that network such that there is or would be a material impact on the terms and conditions of any Connection Offer/ POC Offer / Alternative Connection Offers made in respect of such connections. are Connection Offers/ POC Offers / Alternative Connection Offers made in respect of Interactive Connection Applications. the queue of Affected Parties in receipt of Interactive Connection Offers as defined by us. The original Application Date of an Unsuccessful Applicant that may be retained and carried forward by the Unsuccessful Applicant if they reapply for a new Connection Offer on the same or amended terms during the Reapplication Period, that will be used to determine their relative position in any subsequent Interactive Queue(s) in which they become an Affected Party. Minimum Scheme as defined in Section 8 Glossary of Terms. Moratorium Period a period of 10 Business Days. New Offer Period The period after the Reapplication Period where we will assess the Existing Network and Committed Network and issue new Connection Offers to any Unsuccessful Applicants who reapplied during the Reapplication Period. Notice of Interactivity a notice issued by us in accordance with paragraph [4]. Notice Of Existing a notice issued by us in accordance with paragraph [6] Interactivity Notice Of Outstanding a notice issued by us in accordance with paragraph [15] Interactivity

19 09/12/2014 Notice of Potential Interactivity POC Offer Post Moratorium Acceptance Period Reapplication Period Round of Interactivity Successful Applicant(s) Unsuccessful Applicant(s) a notice issued by us in accordance with paragraph [17] is as described in [of the connection charging methodology]. a period of 5 Business Days following the end of the Moratorium Period. A period of 10 Business Days following valid acceptance of an Interactive Connection Offer during which any Unsuccessful Applicant can reapply for a new Connection Offer on the same or amended terms as their withdrawn Interactive Connection Offer and can retain their Legacy Date as the basis for determining their relative position in any subsequent Interactive Queue(s) in which they become an Affected Party. a Moratorium Period and the corresponding Post Moratorium Acceptance Period, Reapplication Period and, where one or more Unsuccessful Applicants have reapplied for a new Connection Offer during the Reapplication Period, the New Offer Period. the Affected Party or Affected Parties who have accepted their Interactive Connection Offer(s) in accordance with paragraphs [8] and [9]. The Affected Party or Affected Parties in an Interactive Queue who are not Successful Applicants. 3. We will identify where the making of a new Connection Offer/ POC Offer / Alternative Connection Offer would (if accepted) affect the terms of other unaccepted Connection Offer(s)/ POC Offer(s) / Alternative Connection Offer(s). We will notify all Affected Parties at the same time that their Connection Offer/ POC Offer / Alternative Connection Offer is or has become interactive. 4. Notice of Interactivity. At the time of making any Connection Offer/ POC Offer / Alternative Connection Offer that triggers a new Round of Interactivity, all Affected Parties will receive a Notice of Interactivity. The Notice of Interactivity shall: a) inform the Affected Party in writing: that there is another Connection Offer/ POC Offer / Alternative Connection Offer outstanding, the acceptance of which might affect the terms of any Connection Offer/ POC Offer/ Alternative Connection Offer made to it; that its Connection Offer/ POC Offer / Alternative Connection Offer is or has become interactive; its respective position in the Interactive Queue, determined by its Application Date or Legacy Date; and the process for accepting Interactive Connection Offers. b) make the Interactive Connection Offer conditional upon other Affected Parties with priority in the relevant Interactive Queue not accepting their Interactive Connection Offers; and c) suspend an Affected Party s right to accept its Interactive Connection Offer until 9:00am on the next Business Day following the end of the Moratorium Period. A Connection Offer is normally open for acceptance for ninety days after which it will (if not accepted) automatically expire. Where a Connection Offer that has become interactive is due to automatically expire before the end of the Moratorium Period, we

20 09/12/2014 will extend the period for acceptance for that Connection Offer until the end of the Post Moratorium Acceptance Period. 5. The Interactive Queue. The Interactive Queue shall be comprised of the Affected Parties, and an Affected Party s position in the Interactive Queue will be determined by its Application Date or Legacy Date. The Affected Party with the earliest Application Date or Legacy Date will be first, the Affected Party with the next earliest Application Date or Legacy Date will be second, and so on. If two or more Affected Parties have the same Application Date or Legacy Date, they will be given the same (joint) position in the Interactive Queue. 6. Notice of Existing Interactivity. Where a new Interactive Connection Offer is issued by us during a Moratorium Period a new Round of Interactivity will not be triggered. Any new Affected Party will join the existing Interactive Queue, and its position in the Interactive Queue will be determined on the basis of its Application Date or Legacy Date (in accordance with the process in paragraph [5].) Any new Interactive Connection Offer made during an existing Moratorium Period will include a Notice of Existing Interactivity. The Notice of Existing Interactivity shall contain the same information as the applicable Notice of Interactivity sent to the existing Affected Parties in the Interactive Queue, but shall specify the time remaining in the existing Moratorium Period, and shall state that a new Affected Party's right to accept its Interactive Connection Offer will be suspended until the end of the existing Moratorium Period. 7. Acceptance of an Interactive Connection Offer. The Affected Parties will only be able to accept their Interactive Connection Offers at the end of the Moratorium Period. Any acceptance of an Interactive Connection Offer received by us prior to the end of the Moratorium Period will be deemed to have been received at 9:00am on the first Business Day following the end of Moratorium Period. Following the end of the Moratorium Period, any Interactive Connection Offer acceptance received after 5:00pm will be deemed to have been received at 9:00am on the following Business Day. If acceptance of an Interactive Connection Offer is not received during the Post Moratorium Acceptance Period, each Interactive Connection Offer in the Interactive Queue will remain open for acceptance until either: I. it automatically expires; II. a new Affected Party joins the Interactive Queue and a new Round of Interactivity is triggered; or III. an Affected Party accepts their Interactive Connection Offer, all other Interactive Connection Offers in the Interactive Queue are withdrawn, and a Reapplication Period is triggered in accordance with the process in paragraph [10]. 8. The Successful Applicant. The first acceptance received by us following the end of the Moratorium Period shall be valid acceptance and the Affected Party shall be the "Successful Applicant" for that Interactive Queue. If more than one acceptance is received by us on any given day, the Affected Party with priority in the Interactive Queue (in accordance with the process in paragraph [5]) shall be the "Successful Applicant". If two or more Affected Parties have the same Application Date or Legacy Date, and therefore hold the same position in the Interactive Queue, the earliest of such acceptances received by us shall be valid acceptance. 9. Multiple Successful Applicants. The number of Successful Applicants in any given Interactive Queue will depend on the constraint on the network and the capacity

21 09/12/2014 available. Where the constraint on the network allows for valid acceptance of more than one Interactive Connection Offer there may be multiple "Successful Applicants" in that Interactive Queue. After the first Successful Applicant has been determined in accordance with the method in paragraph [8], we will continue to process Interactive Connection Offer acceptances in the order they are received (or when two or more acceptances are received on the same day, on the basis of priority in the Interactive Queue). If any subsequent acceptance can be processed by us without affecting the terms of the existing Successful Applicant's Interactive Connection Offer, it shall be valid acceptance and the relevant Affected Party shall be a "Successful Applicant." For the avoidance of doubt, an Interactive Connection Offer cannot be accepted if the acceptance would displace another Interactive Connection Offer with priority in the Interactive Queue. In the diagram above, if all the acceptances came in on the same day, the 3MVA offer in 4th place could be accommodated onto the 10MVA network capacity with the 1st and 2nd place offers, but the 4th place offer could not be accepted because acceptance would displace the 5MVA offer in 3rd place (which cannot be accommodated onto the network with the 1st and 2nd place offers). Therefore, only the 1st and 2nd place offers will be accepted, and the Affected Parties in 3rd and 4th place will be Unsuccessful Applicants. 10. The Reapplication Period. Following acceptance of any Interactive Acceptance Offer we will provide written notice to: (a) the Successful Applicant that its Interactive Connection Offer has been validly accepted; and (b) any Unsuccessful Applicant that its Interactive Connection Offer has been withdrawn, and that during the Reapplication Period it may: I. re-apply on the same or amended terms for a new Connection Offer; and II. retain its original Application Date as a Legacy Date for the purposes of determining its position in a subsequent Interactive Queue. 11. The New Offer Period. Following the Reapplication Period we shall as soon as practicable during the New Offer Period issue new Connection Offers to any Unsuccessful Applicants who have re-applied on the same or amended terms. If any of these new Connection Offers are or become interactive, a new Round of Interactivity will commence, we will issue a Notice of Interactivity (in accordance with

22 09/12/2014 paragraph [4]) and the position of the Unsuccessful Applicant(s) in any new Interactive Queue will be determined by their Legacy Date. Complex Interactive Queues The basic process we follow where applications for connections become interactive is set out in paragraphs [1 to 11]. However, there are a variety of 'real-world' scenarios that due to the volume of applicants or timing of applications result in complex Interactive Queues. In such situations, we will apply the basic process above, subject to making appropriate modifications specific to the sitatuion. We set out below some examples and our approach to applying the basic process to them. 12. Joining another Interactive Queue due to a new Minimum Scheme. Where the new Minimum Scheme for an Unsuccessful Applicant s re-application results in a Connection Offer which becomes interactive with Connection Offers on another part of the Distribution System, a new Round of Interactivity will be triggered, a new Interactive Queue will be formed and the Affected Parties will receive a Notice of Interactivity. Where that part of the Distribution System already has an Interactive Queue in place, a new Round of Interactivity will not be triggered. The Unsuccessful Applicant will join the existing Interactive Queue in accordance with the process in paragraph [6] and its relative position in the Interactive Queue will be determined on the basis of its Legacy Date. 13. Joining together of Queues. Where a Connection Offer triggers interactivity on a part of the Distribution System which incorporates two or more parts which are already subject to separate Interactive Queues: I. the separate Interactive Queues will be joined to make a new combined Interactive Queue; II. each Affected Parties' relative position in the new combined Interactive Queue will be based on their Application Date or Legacy Date; III. a new Round of Interactivity will not be triggered when the new combined Interactive Queue is formed; IV. the amount of time remaining in the Moratorium Period for the new combined Interactive Queue will be equal to the amount of time remaining in the separate Interactive Queue with the most amount of time remaining; and

23 09/12/2014 V. The Customer shall receive a Notice of Existing Interactivity (in accordance with the process in paragraph [6]) specifying the time remaining in the Moratorium Period and stating that the Customer's right to accept its interactive Connection Offer will be suspended until the end of the existing Moratorium Period. 14. Interactive Sub-Queues. Where an Interactive Queue involves more than one constraint on the Distribution System as per the example below, the order of the Interactive Queue shall be maintained at the highest level of constraint using the Application Date or Legacy Date of each of the Affected Parties. In the diagram above there is a secondary constraint on the network such that 1st and 2nd place in the Interactive Queue cannot be accommodated on the network together. If all the Interactive Connection Offer acceptances in this example were received on the same day, only the 1st place Affected Party would be the "Successful Applicant", because acceptance of the 3rd place Affected Party (which could be accommodated on the network) would displace the 2nd place party. If the Unsuccessful Applicants wished to continue with their applications, they could reapply in accordance with the process in paragraph [10] and a second Round of Interactivity would be triggered. In