1.1. This regulatory review is complementary in scope to the Energy Emergencies Executive Committee’s ‘Storm Arwen Electricity Distribution Disruption Review’ and it will run in parallel.
1.2. The aims of the review are to:
- Establish what happened and set out clear lessons learnt for improvement. The review will draw out good and bad performance, so practice can be improved and issues addressed quickly.
- Determine whether there is any evidence that a network company may have breached any of its statutory obligations or licence conditions, and therefore if Ofgem needs to investigate that further, potentially leading to enforcement action.
- Use the lessons from Storm Arwen to feed into a wider review of climate resilience of network infrastructure and services.
1.3. Our review will cover the following broad areas but will be specifically focused on matters of compliance with statutory and licence obligations; whether companies fell short of their customers’ expectations; and wider regulatory considerations such as the use of price control funding and the compensation arrangements.
- Assessment. An assessment of the issues or problems that arose, what caused them and their impact on customers.
- Network resilience. An assessment of network investment and maintenance in areas that experienced faults: looking at the condition and associated maintenance records for these assets; whether they were appropriately designed and constructed, given the environment in which they operate; and whether proximity of lines to trees has been appropriately managed.
- Planning and preparation. Did companies have advance knowledge or insight into problem areas in their networks that might be adversely impacted by the weather conditions experienced? What did companies do proactively in advance of Storm Arwen to prepare themselves and customers and to mitigate risks? Were the emergency plans in place adequate to cope with the problems and have lessons been learned from previous incidents (e.g the Christmas 2013 storms)? Were those emergency plans appropriately enacted?
- Handling of incidents. What did companies do to deploy resources to deal with problems including distribution of generators, speed and effectiveness of repairs, management oversight and governance, and accessing engineering support from other companies? How did companies prioritise their resources and deal with incidents where customers were severely impacted or off supply for long periods of time?
- Communication and support during the incident. How well did companies communicate with customers and stakeholders during the incident? Did they work appropriately with local authorities to identify and support all customers that might be impacted adversely by the event? How well were customers in vulnerable circumstances identified and supported (including customers on the Priority Services Register)?
- Ongoing support after the incident. How were customers looked after following the event, particularly in terms of providing fair and speedy compensation, and any ongoing support required?
1.4. It is possible that extreme weather events may become more frequent with climate change. The longer-term aspects of the review will consider what we can learn from this case to strengthen network resilience to extreme weather events in future. It will help us critically assess companies’ approaches and identify measures to strengthen network resilience, both in terms of the robustness of the physical infrastructure; and the speed of restoration of power in the event of network failures caused by extreme weather or climate factors.
1.5. We will be engaging with and requesting information from network companies across the electricity transmission and distribution sectors. We will also be speaking to and seeking input from customers who were directly affected, particularly those that have had to endure long power outages; as well as local authorities, local rural communities and resilience fora, and business representatives. For certain aspects of the review, we may rely on information and evidence gathered from the Government’s review.
1.6. We plan to report on our conclusions in spring 2022. As part of this we would expect to establish whether any companies have fallen short of their obligations to customers. We will aim to provide an update on any initial findings early in the new year.
1.7 Following this we plan to take forward any longer-term issues in our wider review of climate resilience as outlined above, with a clear plan in place.