CMP402: Introduction of Anticipatory Investment (AI) principles within the User Commitment Arrangements
What is being proposed
In response to Ofgem’s final decision on Anticipatory Investment (AI) dated 18 October 2022, changes to the current User Commitment provisions as detailed within CUSC Section 15 are required to introduce the AI principles for offshore generators connecting at different times to non-radial offshore transmission network
Current status
The Panel met on 25 November 2022 and agreed that it goes to a Workgroup. Workgroup Consultation was issued on 24 May 2023 and closed 21 June 2023, and received 5 non-confidential responses. The Workgroup Report was scheduled to be presented to the July 2023 CUSC Panel, however an updated timeline was approved for the Workgroup Report to be presented at the August 2023 CUSC Panel. A new timeline was approved by the August 2023 CUSC Panel for approval. The Workgroup Report was scheduled to be issued to the September 2023 CUSC Panel, however an updated timeline was approved at the September 2023 CUSC Panel for the Workgroup Report to be submitted to the October 2023 CUSC Panel. The Workgroup Report was scheduled to be issued to the October 2023 CUSC Panel, however the Proposer provided a progress update on the clarity required on the solution including analysis to justify the numbers being codified into the CUSC, the work required on the new WACMs to the October 2023 CUSC Panel. An updated timeline was presented to the December 2023 CUSC Panel. The December 2023 CUSC Panel approved an updated timeline, including for a second Workgroup Consultation to be issued. The next Workgroup meeting will be scheduled once the Proposer has confirmed next steps with The Authority. Ahead of the CUSC Panel approving the reconvening of Workgroup meetings, the Proposer will be developing a new solution. The Proposer reached out to Workgroup members on 13/06/24 with a solution update requesting feedback. October 2024 CUSC Panel prioritised as Medium, therefore Workgroup activity will start from Spring 2025. On 14 February 2025 at the Special CUSC Panel the Panel discussed, at length and in detail, the prioritisation of CUSC Modifications. The CUSC Panel agreed this modification remained medium priority. (08/09/2025) In the postponed 03 September Panel, the Panel moved this modification prioity to low.
Details
Timeline
Analysis
CMP402 would modify CUSC Section 15 to implement Ofgem's October 2022 anticipatory investment principles for offshore generators connecting to shared transmission networks at different times. The modification has been deprioritised to low priority by the CUSC Panel as of September 2025, with no active workgroup meetings scheduled.
Why it matters
This addresses cost allocation for transmission built ahead of need but remains stalled in process — anticipatory investment shifts risk from developers to consumers through socialised network costs. The repeated delays and deprioritisation suggest limited industry appetite for resolving the user commitment arrangements that determine who pays for stranded assets.
Key facts
- •Responds to Ofgem's 18 October 2022 anticipatory investment decision
- •Affects CUSC Section 15 User Commitment provisions
- •Deprioritised to low priority September 2025
- •Applies to offshore generators connecting to non-radial offshore transmission networks
- •Multiple timeline delays since November 2022