Connection and Use of System Code (CUSC) CMP448: Introducing a progression commitment fee to the Gate 2 connections queue

What this is about

CMP448 puts a price on holding a place in the reformed connections queue. It introduces a progression commitment fee for projects that have been allocated a Gate 2 position under the TMO4+ Connections Reform package, payable as a condition of taking and keeping that slot. Ofgem's October 2025 consultation set out a minded-to position to approve the Original Proposal; the December 2025 update confirms the outcome: approved, with 40 responses received (25 non-confidential, 15 confidential).

The reason it exists is the central pathology of the GB connections queue. A connection offer that costs nothing to hold is a free option on grid capacity. A developer who is unsure whether a project will proceed has every reason to keep the slot rather than release it, because the slot has option value and carrying it is free. Multiply that across a queue measured in hundreds of gigawatts and the result is the queue GB now has: more capacity holding positions than will ever be built, projects that are progressing stuck behind projects that are not, and a NESO that cannot tell the difference because nobody has had to reveal it. TMO4+ rebuilds the queue around a "first ready, first connected" logic and gates entry behind readiness criteria. CMP448 is the financial half of that logic: once a project is through Gate 2, it must pay to keep its place, and that payment is structured to force a periodic self-assessment of whether the project is genuinely going ahead. The fee is the cost that makes the option no longer free.

The design question, which is where the substance sits, is whether the fee is large enough to do that work. A commitment fee set too low becomes a line item, a routine cost of doing business that speculative and serious developers both absorb without changing behaviour, in which case the queue is reordered on paper but not disciplined in practice. Set high enough, and refundable or creditable against connection costs for projects that deliver, it changes the calculation for a developer holding a slot it does not intend to use: the option now has a running cost, and the rational move is to release capacity rather than pay to sit on it. The impact assessment Ofgem published alongside the consultation is the document that argues the chosen calibration achieves the former without unduly penalising legitimate projects facing delays outside their control. That trade-off, deterrence versus proportionality, is the entire policy.

How to respond

This consultation has closed and is no longer accepting responses. It was published on 20 October 2025 and closed on 4 November 2025, a 15-day window. Ofgem's stated submission route was by email to connections@ofgem.gov.uk, and respondents were particularly sought from project developers, electricity generators, NESO, and network companies (transmission owners and DNOs).

The outcome is now settled. On 8 December 2025 Ofgem published the decision document, the full set of non-confidential consultation responses, and the confirmed CUSC modification. The decision is to approve Original Proposal CMP448. Anyone tracking this should go to the primary documents rather than the consultation page:

- Decision: CUSC CMP448 [PDF, 219KB] — Ofgem's reasoning and response to consultation feedback. - CMP448 Impact assessment [PDF, 1.06MB] — the analysis behind the fee design, including the calibration argument and Ofgem's case for the Original Proposal over alternatives. - Consultation responses [ZIP, 8.5MB] — 25 non-confidential responses, redacted where necessary. - Decision on Connections Reform Package (TM04+) — the parent decision CMP448 sits within; read this for how the fee interacts with the wider Gate 2 readiness criteria.

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A note on what this memo does not contain. The structured analysis passed to me identified no distinct options and no consultation questions, and the truncated source text is the Ofgem publication page rather than the consultation document or impact assessment, so it carries none of either. I have not invented an options matrix or a question list to fill those sections; the consultation document [PDF, 281KB] and the impact assessment [PDF, 1.06MB] are where the alternative fee designs Ofgem considered and any formal consultation questions will be set out.

If a fuller memo is wanted, the next step is to ingest the CMP448 consultation document and impact assessment PDFs and the December decision document. That would let me reconstruct the options Ofgem weighed (fee level, refundability, payment timing, treatment of delayed-but-genuine projects), summarise how the 25 non-confidential respondents split, and assess against the decision whether the approved calibration is set to materially deter speculative queue-holding or will function as routine cost-of-doing-business. Say the word and I'll pull those sources.