CMP471 Urgency Request Letter

What this is about

CMP471 is a temporary CUSC fix that lets queue holders adjust connection dates and other contract elements before the first CMP434 Gated Application Window opens. Muirhall Energy raised it on 17 April 2026. The CUSC Panel considered it on 15 May 2026 and unanimously recommended urgent treatment. Ofgem's decision on urgency is due by 5pm on 19 May 2026. If granted, the modification implements on 31 July 2026. If refused, it slips into the standard timetable with implementation "TBC" sometime in 2027, after the 1 April 2027 liability trigger has already fired.

The trigger matters. From 1 April 2027, Users carrying connection dates in their contracts face a step change in liability exposure tied to those dates. Connections reform (CMP434) then funnels them into Gated Application Windows where their contractual dates are tested against Gate 2 criteria. The Proposer's case is that many Users hold contractual connection dates that no longer reflect what their projects can actually deliver, and that without a pre-Gate 2 window to amend them, they will either reject Gate 2 Offers or absorb cost exposure tied to programmes they cannot meet. The Panel agreed this is a significant commercial impact (Ofgem Urgency criterion (a)) with a fixed deadline that a standard 11-month timetable cannot meet.

The substantive question for Ofgem is not really the timetable. It is whether to soften the discipline CMP434 was designed to impose. CMP434's logic is that contractual connection dates should mean something, and that Users carrying undeliverable dates should bear the cost of having claimed them. CMP471 lets those Users rewrite the contract before the bill arrives. That helps the queue holders who currently sit on stale dates. It also extends the life of contracts that the reform was built to flush out.

Options on the table

The Panel paper presents one substantive proposal (CMP471 itself) with two timetable variants. The choice Ofgem actually faces is binary: grant urgency or refuse it.

Grant urgency, implement 31 July 2026

This is what the Panel and the Proposer want. Workgroup runs through May and early June, code administrator consultation closes 30 June, Panel votes on the Draft Final Modification Report on 10 July, Ofgem decides by 17 July, and the new variation process is live on 31 July. That gives Users roughly eight months between implementation and the 1 April 2027 liability trigger to use the interim variation process to align contractual connection dates with deliverable programmes.

Who wins: existing queue holders with stale dates, particularly those whose original contractual connection dates were set on optimistic delivery assumptions and who would otherwise enter Gate 2 carrying programmes they cannot defend. Developers who have been holding queue positions on capacity they cannot bring forward also win, because the variation process lets them reset the date without losing the position. NESO wins to the extent that Gate 2 rounds run more cleanly when Users arrive with credible dates rather than rejecting offers on arrival.

Who loses: the integrity of the CMP434 timetable, and by extension the consumers who fund the reform. The 1 April 2027 trigger was set to impose a cost on holding undeliverable dates. CMP471 lets Users avoid that cost by amending the dates before the trigger fires. New entrants who would gain queue access faster if incumbent holders were flushed out via Gate 2 also lose. The slower the queue clears, the longer they wait.

The compressed timetable itself carries process costs. Workgroup consultation drops below 15 business days. Code administrator consultation drops below 15 business days. There are fewer than 5 clear business days between the Draft Final Modification Report and the Panel recommendation vote, and fewer than 5 clear business days for Panel to verify the vote was recorded correctly. These are not nominal abbreviations. They reduce the time available for industry parties to scrutinise the drafting of the variation process itself, which determines how broad the relief actually is, what counts as a permissible adjustment, and how NESO assesses each request. Drafting errors locked in on this timetable are harder to catch.

Refuse urgency, follow the standard timetable

The standard timetable presented in Appendix 2 has implementation date "TBC" but the path leads through Ofgem decision in April 2027 at the earliest. That is after the 1 April 2027 liability trigger has already passed. On this path, CMP471 either lands too late to do its intended job or is abandoned.

Who wins: the CMP434 reform programme. Users who cannot defend their contractual connection dates enter the first Gated Application Window with those dates intact and are tested against Gate 2 criteria as the reform designed. Termination payments and Gate 2 rejections fall on the parties whose original date claims were optimistic. The queue contracts. New entrants gain access faster.

Who loses: existing queue holders carrying stale dates, who face larger cost exposure than they would under the urgent route. Some of those holders will be projects that genuinely could deliver but on a revised timetable, and the standard route gives them no orderly exit. The crudeness of the test is the point of CMP434, but it is also the cost.

Questions being asked

The letter itself is a Panel request for an urgency decision, not a consultation document with numbered questions. Ofgem's decision is binary (urgency granted or refused) with a defined deadline. The substantive consultation questions on the policy content of CMP471 will follow during the Workgroup Consultation (3-9 June 2026 on the urgent timetable) and the Code Administrator Consultation (23-30 June 2026 on the urgent timetable). Those question sets are not in this document.

For respondents who want to influence the policy content rather than the urgency decision, the relevant inputs are:

On urgency

Whether the imminent 1 April 2027 liability trigger and the first CMP434 Gated Application Window together constitute a significant commercial impact under Ofgem Urgency criterion (a), such that the modification cannot wait for a standard timetable. (The Panel says yes, unanimously. Ofgem's call is whether the commercial impact is significant enough to override the procedural costs of the abbreviated timetable.)

On policy content (for the consultations that follow)

What contract elements should be amendable under the interim variation process. (Connection date is the headline. Whether the variation can also cover capacity, technology, or other commercial terms shapes how far the relief reaches and how much of CMP434's discipline it dilutes.)

How NESO should assess each variation request. (A high bar limits use to projects that can show genuine programme slippage. A low bar makes it a routine reset for any User who wants one.)

Whether the variation process should sunset on a defined date or persist into the Gated Application Window regime. (The Proposer frames CMP471 as temporary and pre-Gate 2. The drafting needs to make that stick.)

Whether Users who variate under CMP471 should face any consequence (forfeited security, reduced priority, fee) or whether the variation is cost-free. (Cost-free variation maximises the dilution of CMP434. A fee or security adjustment preserves some of the discipline.)

How to respond

This letter is addressed to Nadir Hafeez at Ofgem and signed by Anthony Pygram, Independent Chair of the CUSC and Grid Code Panel. It is a Panel request for an urgency decision under CUSC Section 8.24.4, not an open consultation. Ofgem's response on urgency is due by 5pm on 19 May 2026.

For industry parties wanting to engage with the substance of CMP471 rather than the urgency decision, the relevant routes (assuming urgency is granted) are:

- Workgroup Consultation: 3 June 2026 to 9 June 2026. Less than 15 business days. Open to all CUSC parties and interested stakeholders. Submitted via the CUSC modification page on the NESO website. - Code Administrator Consultation: 23 June 2026 to 30 June 2026. Less than 15 business days. Same submission route. - Workgroup attendance: Workgroups 1-3 run 26 May, 29 May, and 2 June 2026. Workgroups 4-5 run 11 June and 15 June 2026. Workgroup nominations open 15-19 May 2026.

If urgency is refused, the standard timetable opens Workgroup Consultation from 8 October to 29 October 2026 and Code Administrator Consultation from 8 February to 1 March 2027, but on that path the modification likely arrives too late to serve its purpose.

All CMP471 documentation is on the NESO CUSC modifications page. Questions on the letter or the proposed process should go to Anthony Pygram in his capacity as Independent Chair of the CUSC and Grid Code Panel. Contact details are not given in the body of the letter; the standard route is via the CUSC Code Administrator at NESO.