Northern Powergrid (Yorkshire) plc
Strategic Report for the Year Ended 31 December 2021 (continued)
As the Company transitions into the ED2 period, decarbonisation will continue to become central not only to the
Company’s strategy, but the way in which the Company contributes more broadly to the evolution of the energy
industry and the stakeholders with whom it interacts. The Company has been progressive in its ambition to
reduce its own business carbon footprint. However, more is required and it is acknowledged that the Company
has a key role to play in facilitating regional decarbonisation by fulfilling the functions of Distribution System
Operation (DSO). This means investing in people, processes and systems in order to actively manage the
Network and to optimise the use of assets and generated energy in the region.
As part of the Company’s ED2 Plan submission, a number of strategic objectives shaped the development of the
accompanying DSO strategy. This included ‘flexibility first’, involving deploying flexible solutions as an
alternative to Network reinforcement, ‘whole system collaboration’ in order to engage with the wider market on
whole system energy solutions, ‘data and digitalisation’, to facilitate solutions in areas such as open data,
‘openness and transparency’ to collaborate in joint planning with our stakeholders and, finally, fostering a
‘workplace and workforce fit for the future', to build regional and national skills.
Collectively, these objectives have been developed to achieve a number of outcomes and benefits, including to
enable open energy data sharing, transform the way decisions and plans are made throughout the Company,
support the development of new flexible energy markets, increase customer and Network flexibility and
facilitate a whole system energy system. During the remainder of the ED1 Period, the Company will continue to
build on the significant activity that has already been undertaken to decarbonise its operations and reduce the
impact that it has upon its stakeholders as it prepares for the implementation of the ED2 Plan.
REGULATORY INTEGRITY
Strategic objective:
Trustworthy, fair and balanced.
KPI:
Completion of a quarterly regulatory compliance affirmation process.
Business Plan commitment:
To manage the Company's business to the highest behavioural standards and
adhere to a policy of strict compliance with all relevant standards, legislation and regulatory conditions.
Performance during the year
: In order to assure compliance with distribution licence and other regulatory
obligations, the Company operates a regulatory compliance affirmation process, under which ownership of
approximately 2,000 regulatory obligations is assigned to 74 responsible managers. Those responsible managers
are required to review compliance with the relevant obligations on a quarterly basis and report on any identified
non-compliances or perceived risks which are then addressed by members of the senior management team. To
minimise the risk of the Company breaching its licence conditions and other statutory requirements (which
could lead to financial penalties), the board reviews the outcomes of each exercise. Each quarterly regulatory
compliance affirmation process was completed satisfactorily during the year.
The Company submitted its annual Data Assurance Report to Ofgem in February 2021, which included risk
assessments of the regulatory returns to be submitted for the Regulatory Year ahead (April 2021 to March
2022), together with a report detailing the assurance work actually carried out in the year ended 28 February
2021 and the findings of that work.
Ofgem is undertaking its review process to determine the charges that DNOs are able to levy over the next price
control period (the ED2 period), which will run from April 2023 to March 2028). This process is following the
sector-specific methodology that Ofgem published in December 2020 and March 2021. These decisions
indicated the outputs and uncertainty mechanisms that are likely to apply and also set working assumptions for
the allowed cost of capital parameters, all of which are subject to finalisation. The process is expected to
conclude with final determinations in December 2022, with draft determinations in mid-2022.
In December 2021 the Company published and submitted to Ofgem its finalised business plan for the ED2
period. The ED2 plan involves £661.3 million in annual investment, a 41% increase on the comparable measure
over the ED1 period (April 2015 to March 2023). It is now subject to regulatory evaluation by Ofgem as part of
its ongoing price review process.
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