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Please find attached a document intended to be a response to questions 1 and 3 in Annex A: List of Questions in your call for evidence. It is perhaps worth pointing out that this looks at an aspect of distributed generation which has not been specifically considered in your document. - the provision of short term reserve generation plant to NGC. Short term reserve from other sources is quite a significant source of CO2 emissions and this proven technology has the capability of reducing those emissions by perhaps 80%. With suitable encouragement this could be achieved within three years.
Wessex Water have a project in hand to extend their existing provision of short term reserve generation plant. This submission has been prepared by the project manager who is a power distribution and appllications specialist. It reflects difficulties now being experienced in delivering a viable project.
These remarks are to support our submission:
1. In the second paragraph of' 'Load Management using standby generators' I stated that that CO2 would be reduced by 80 to 90%. This statement is based on DTI report K/EL/000346/00/00. Your report concludes that 300/750 tonnes of CO2 emissions are avoided for every megawatt of reserveprovided this way. As we are looking at perhaps 2GW, this is indeed an easy prize in any CO2 reduction programme. Work could be completed within about 2 to 3 years given appropriate price signals.
2. I challenge the assumption that the distributed generator should bear the cost of modifications when the generator is on an existing connection. The distribution company (DNO) already gets paid a considerable inducement to encourage distributed generation. In addition the distributed generation reduces the DNO's triad charges and losses.
Modifications to the service connection involve no wayleaves and should not carry the same overheads as new connections. Indeed the connection of distributed generationat existing points of supply should be at nominal cost.
3. On a current project,Scottish and Southern refuse to accept an order for more than 4 studies at a time thus dragging out what should be a few weeks in a project to potentially an year. I asked for 27 such small studies. This would appear to be an administrative device to overcome the OFGEM service requirement to give quotations within a specified period.These are the studies referred to in my main submission where I had to negotiate for an extended period to reduce the charge per study from £5000 to £500. They have also given budget costs for the connection modifications where export into their network is practical of £30000 compared with £17000 in other parts of the UK. I would argue that there is a strong case for OFGEM imposing uniform service conditions and very modest charges for the connection of distributed generation.