Regional Energy Strategic Plan Policy consultation on Licence Modifications and Guidance Document

What this is about

Ofgem is consulting on the licence drafting needed to put Regional Energy Strategic Plans (RESPs) into NESO's statutory remit, with mirror obligations on the electricity distribution licensees and the gas transporters. This is the policy-stage consultation that runs ahead of the formal statutory consultation. The April 2025 RESP framework decision established what RESPs are. This consultation turns that framework into licence text.

A RESP is the regional layer of network planning. The Centralised Strategic Network Plan (CSNP) covers the transmission system. DNO and GDN investment cases sit at the distribution level. Between them was a gap: nothing produced a spatially-resolved view of where demand and generation would land at sub-regional scale, in a form the network companies could actually plan against. NESO is being given that job. The licence modifications consulted on here cover four instruments: the Electricity System Operator Licence, the new Gas System Planner Licence, the Standard Conditions of the Electricity Distribution Licence, and Part D of the Standard Special Conditions of the Gas Transporters Licence. An associated RESP Guidance document sets out what Ofgem expects NESO to produce and what it expects the network companies to contribute.

The architectural point: NESO becomes the regional planner, the DNOs and GDNs become statutory participants in NESO's process rather than the originators of their own spatial demand forecasts, and Ofgem becomes the body that judges whether the plan was developed properly and whether the network companies engaged with it. This is a significant centralisation of planning authority into NESO, layered on top of its existing transmission, balancing, and CSNP roles.

Options on the table

The source text does not flag distinct options in the consultation. This is the standard Ofgem pattern for a licence-drafting consultation: there is one proposed approach (the draft licence text in Annexes A-D and the draft Guidance in Annex E), and Ofgem is asking whether the drafting works rather than asking respondents to choose between alternative designs. The strategic options were settled at the April 2025 framework decision. What is open here is implementation detail: which obligations sit in licence conditions versus the Guidance, how the duty to "have regard to" the RESP is drafted on the network companies, and how disputes between NESO and the network companies are handled.

Questions being asked

The consultation document is not reproduced in full in the source text, so the specific question numbering is not available. The structure below reflects the four licence instruments being modified and the Guidance, which is how the consultation document is organised.

Electricity System Operator Licence (Annex A)

Questions on whether the proposed obligations on NESO produce a workable RESP duty. This covers the scope of the plan, the geographic units (the RESP regions), the cadence at which RESPs are refreshed, the data inputs NESO is entitled to require from distribution licensees, and the relationship between RESP outputs and NESO's existing CSNP and Future Energy Scenarios work. [The substantive question is whether NESO has enough authority to compel distribution-network data and stakeholder participation, and whether the RESP outputs are binding on anyone or only advisory.]

Gas System Planner Licence (Annex B)

This is a new licence created to hold the gas-side equivalent of the ESO planning obligations. Questions cover whether the GSP licence text correctly mirrors the ESO licence for gas, where gas-specific drafting departs from the electricity drafting, and how the GSP and ESO functions interact within NESO. [The underlying issue is whether gas planning should be on equal footing with electricity planning or treated as a secondary input, given that the long-run trajectory for gas networks is contested.]

Electricity Distribution Licence Standard Conditions (Annex C)

Questions on the new obligations placed on DNOs to participate in the RESP process. This includes providing data, attending stakeholder forums, having regard to the RESP in their own investment planning, and reporting on how the RESP has shaped their plans. [What "have regard to" means in practice is the key drafting question. A weak formulation lets DNOs cite the RESP and continue as before. A strong formulation gives Ofgem grounds to challenge DNO investment cases that diverge from the RESP, which changes the balance of authority between NESO and the DNOs.]

Gas Transporters Licence Part D (Annex D)

Mirror questions for the GDNs. Same structural issues: what data they must provide, what weight they must give the RESP, how engagement is documented. [The gas-network framing matters more here because GDN investment decisions over the RESP timeframe will turn on whether networks are being repurposed, decommissioned, or maintained, and the RESP is the instrument that will shape that view region by region.]

RESP Guidance document (Annex E)

Questions on the Guidance that accompanies the licence text. The Guidance sets Ofgem's expectations for how NESO delivers the RESP and how the network companies participate. Themes include the methodology NESO should use, the stakeholder engagement process, how RESPs handle uncertainty (multiple scenarios versus a central case), how RESPs are revised when underlying assumptions change, and the form of the published output. [The Guidance is where most of the operational substance sits. Licence conditions create the duty; the Guidance defines what discharging the duty looks like. A consultation respondent who wants to shape what RESPs actually contain should focus their response here rather than on the licence drafting.]

Cross-cutting

Questions on the interaction between the RESP, the CSNP, distribution network investment plans (the RIIO-ED2 and ED3 frameworks), gas distribution investment plans (RIIO-GD3), and local planning by combined authorities and the Strategic Spatial Energy Plan. [The institutional crowding around regional planning is real: NESO, Ofgem, DESNZ, devolved governments, mayoral combined authorities, and the network companies all have a stake. The consultation is asking respondents to flag where the proposed licence drafting creates duplication, conflict, or unallocated responsibility.]

How to respond

Original consultation deadline: 8 August 2025 (the published "closed date" of 9 August reflects the next working day after the deadline). Response email: resp@ofgem.gov.uk.

The consultation is now closed. The statutory consultation that followed ran from 16 October 2025 to 28 November 2025 and is also closed. Ofgem published the licence-modification decision on 18 March 2026, which is what the "Closed (with decision)" status on the consultation page refers to. Anyone reaching this page now should read it as background to the March 2026 decision rather than as a live consultation. The substantive document to engage with is the decision itself and the published responses (linked from the page as the RESP policy consultation responses ZIP).