Distributed Generation
FINAL PROPOSED POLICY on Letters of
Authority (LOAs) for large (G59) distributed
generation connection requests
Background
Currently Connections process all applications for connection quotations regardless
of the applicant’s status. Due to the high volumes of Distributed Generation (DG)
applications currently being received in particularly in the EPN and SPN areas UKPN
is providing poor customer service in terms of time to quote, and is at increased risk
of licence breach with regards to the timeliness of issued quotes.
Having been notified that other DNOs require a Letter of Authority (LOA) from
generation connection applicants a ‘New Matters Form’ was raised with the Legal
team to clarify possible use of LOAs to manage volumes of applications. Their advice
concluded that ‘in principle, it is possible to construct an argument around LC12 and
Section 16 of the Electricity Act 1989 (Act) to justify requesting a letter of authority (LOA)
from generation applicants. However, whilst the requirement may be possible in principle, it
would mean a change in connections policy which raises a number of important
considerations’.
These have been taken in account in the development of this policy.
A number of other DNOs (not all) also require Letters of Authority for some or all
applicants. Responses form the other DNOs are in Appendix 1
Stakeholder Engagement
DG has been an area of growth for the last 2-3 years. Recognising this we
introduced in late 2012 the first of a series of planned Customer Experience
Workshops specifically for the DG community. These provide the opportunity for
customers to meet with us to share their concerns and for us to share our plans for
improving levels of customer service via a DG Service Improvement Plan.
Since their introduction we have now held five workshops. These have been well
attended and we’ve take the opportunity to share with the attendees our intention to
introduce a requirement for Letters of Authority to accompany grid connection
requests for large (G59) DG projects. At the last workshop on 27 February 2014 all
attendees were given the opportunity to provide feedback and there no challenges.
Policy Change Proposal

With effect from 1 June 2014 Connections will only process requests for large
(G59) DG connection applications in EPN and SPN where the applicant has
either confirmed they are the owner/occupierr or hold a Letter of Authority
from the owner/occupier
What applications will this apply to?

All requests for non-contestable only quotations or full ‘s16’ quotations, where
the applicant requires a generation connection in either EPN or SPN
PLEASE NOTE WE CANNOT REQUEST A LETTER OF AUTHORITY FROM AN
IDNO

We can require a LOA for all section 16 applications but at this time are
enforcing it for DG connections only
How long will this continue for?

The policy is not intended to be temporary but will be subject to review when
external or internal changes dictate, for example if upfront charging of A&D
were re-introduced
Why not LPN?

Volumes of generation applications in LPN are manageable
Why not Demand connections?

Volumes of demand quotations are manageable. The technical expertise of
these applications is not as specific as that of generation.
Who will check whether an application has a Letter of Authority?

Gateway
What will UKPN offer where an applicant does not have a Letter of Authority?

A Free Budget Estimate or a Feasibility Study (Chargeable)
How will we communicate this proposed change to the DG Community?




Communication with all relevant UKPN Connections employees
Email to all DG customers on our database in early May
Update to website following email to customers
DG CEW on 22 May 2014
Process
1. Applicant submits application to Gateway.
2. For relevant applications Gateway checks basic information and returns the
application to the customer with a standard response if there is neither an
apparent Letter of Authority nor a statement to the effect that the applicant
is the land owner or occupier
a. The standard response requests that the applicant confirms that they
are the land owner or occupier or that they are acting on behalf of the
landowner as an agent and
b. Informs the applicant that they can apply for a free Budget Estimate or
a Feasibility Study (the latter being chargeable)
3. Applications will not be processed until ownership has been confirmed or until
a LoA has been received
4. Where the applicant requests an IDNO quotation in the same e-mail as a s16
/ ICP option and the LoA / land owner/owner confirmation is missing, the
IDNO application must be set up and processed as normal.
5. Where applications are received with an apparent Letter of Authority Gateway
will process the application as normal setting up in CQS / CiC2 / GRT as
appropriate, and passing through to Projects Prelims / CiC / Major
Connections(i.e. the assumption is that the LoA or statement of
landownership is valid)
6. The responsible team (i.e. the team dealing with the application) will be
responsible for checking the validity of any Letters of Authority received. This
is not necessarily checking all LoAs but a small regular sample. Checks
would include whether the land in question relates to that in the application
If the clock has started, i.e. it is an ‘in-flight’ application, i.e. we have received a LoA or
confirmation of land ownership, then either Exempt the job under 5.7 (e) and cancel the
quote, or issue the quote with a condition that ‘an additional requirement for acceptance of
this quote is provision of a suitable LoA’.
In each case a judgement call will be required on whether to issue a (conditional) quote or to
exempt. As always suitable notes must be recorded in project files, and clear communication
to customer on our course of action made.
Letter of Authority
A Letter of Authority will need to be provided for large (G59) DG applications in EPN
and SPN areas.
A model form of Letter of Authority is provided in Appendix 2
Large (G59) Generator Checklist
A checklist for use by customers is provided in Appendix 3
Appendix 1





WPD: Official Company line is that we may request a LoA for all applications
where the person applying is not the owner or occupier. In practice however,
we tend to relax the requirement with the exception of generation enquiries.
[NM requested clarity] Yes, we will ask them for the LoA before providing the
quotation.
SSE: Very similar to WPD - we may request a LoA for all applications where
the person applying is not the owner or occupier (or an IDNO). In practice
however, we always ask for one from any ICP (POC because it’s an ICP we
are quoting) or generation (POC or Section 16) enquiries - where there is a
genuine reason to require the LOA based on [our] experiences. If they cannot
provide a LOA we give them a budget estimate.
SP: We certainly request this with all DG applications
NPG: We tend not to ask for a LOA as a matter of course but there may be
circumstances where it is necessary.
ENWL: We’d general [sic] not require a Letter of Authority
Three DNOs, WPD, SSE and SP, appear to require Letters of Authority for a subset
of applications i.e. generation (and in the case of SSE ICP applications as well (!))
NPG and ENWL both appear to not require a Letter of Authority but neither have
slammed the door shut.
Appendix 2
MODEL FORM OF LETTER OF AUTHORITY
To whom it may concern
Re: [Address of property] grid application
We [insert name] of [address of property] confirm that we are the legal and registered
owner/occupier of the land situated at [address of property], as outlined red within the
plan below.
We would like to confirm that we have appointed [name of Company appointed] to
develop a [confirm type of technology] on our land and hereby grant permission for
them or any consultant that they may authorise to seek and apply for a grid
connection on our land for the purpose of connecting a [confirm type of technology]
project to the local electricity distribution network.
Signed…………………………
Name (CAPITALS)…………………………………….
Date…………………………….
[insert plan]
Sample Plan (shown below) to be OS based clearly showing the boundaries of the
land referred to above.
Appendix 3
LARGE (G59) DG CONNECTION APPLICATION CHECKLIST
G59 CHECKLIST PLEASE SUBMIT THIS FORM WITH YOUR
COMPLETED ENA APPLICATION FORM FOR A G59/3 GENERATOR CONNECTION
How firm are your proposals?
Alternatives available to you
If your proposals are not firm
Budget Estimate
Feasibility Study
Description
Please indicate your
requirements
A basic desktop estimate without any system studies. It is
not a binding offer on you or us
A chargeable electricity system study to give a more
detailed view of the likely price of connection for various
options
If you know what and where you want to connect
Section 16 Connection Offer
UK Power Networks will quote for undertaking all the
contestable and non-contestable works
Standard Licence Condition 15 CIC
UK Power Networks will quote for undertaking the nonConnection Offer
contestable works only. You MUST arrange to undertake
the contestable works.
IDNO Point of Connection Application
UK Power Networks will quote for providing a point of
connection to our network only
What to send to us
Included Y/N
1
Completed ENA G59 application form containing all contact details and appropriate technical
details
2
Site Plan as follows
At a scale of at least 1:500
Including the six figure X, Y OS grid co-ordinates
Showing some identifiable landmarks such as roads
Showing the proposed site boundary
Showing the proposed loaction of incoming connection point
3
A Letter of Authority (LOA)* from the landowner or occupier (a model form letter can be found
on our website) where the applicant is acting as an agent of the occupier or landowner
4
5
6
A single line diagram (SLD) electrical schematic diagram of the proposed installation
showing: the location of the protection systems, the associated automaticee disconnecting
devices, the interfac with UK Power Networks and the customers network including loads,
generators, transformers, circuit breakers and cables etc.
Fault level data - this is the fault level contribution from your installation/equipment into UK
Power Networks network (not the rating of your equipment) at your preferred connection
voltage
Details of harmonics and flicker, and any other disturbing equipment you plan to connect
Your application will not be processed if any of the above are missing
Where to send the application to:
Please email both your application form and this checklist to: connections.gateway@ukpowernetworks.co.uk
* The requirement for a Letter of Authority is effective for all new applications from 1 June 2014.
Applications received without an accompanying Letter of Authority will not be processed.