4 The electricity wholesale market
60. The big omission from the Government's set of
objectives is reform of the electricity wholesale market itself.
As it stands, "Electricity Market Reform" is a misnomer.
The core of the electricity marketthe wholesale marketwould
not be changed by the measures proposed in the Consultation Document.
Rather, the Consultation proposes a number of "bolt on"
measures that reform the subsidies and structures around the market,
not the market itself. In this Chapter, we consider structure
of the electricity market and the importance of liquidity and
how these factors will influence the outcomes of Electricity Market
Reform.
The need for reform of the wholesale
market
61. We heard that improving the way that the market
operates is vital. It will be necessary to attract new investment
in the sector and to underpin the operation of the measures proposed
in the Consultation. The Government is attempting to create a
system that will be sustainable for the long-term. In order to
achieve a long-lasting electricity market structure that delivers
all three of the Government's objectives, it will be necessary
to address the core of the market itself. However, the Government
continues to delegate that responsibility to the regulator, Ofgem,
which has so far been unable to break through the dominance of
the "Big Six" vertically integrated players (Centrica,
E.ON, RWE npower, SSE, Scottish Power and EDF) to create a fully
effective electricity market.
62. Professor Dieter Helm expressed how the objectives
of EMR were jeopardised by the status quo in the electricity wholesale
market:
The problem for Ofgem is that, having finally admitted
in Project Discovery that security of supply would not
be achieved by the marketit claimed for a long time that
it would beit now has to go one stage further and admit
that liquidity and transparency, and NETA, do not mix.[65]
63. He argued that "what happens to NETA in
the FITs long-term contract world and the capacity market is not
discussed in the document" and suggested returning to a system
that resembled previous electricity trading arrangements known
as "the Pool", which required virtually all electricity
in England and Wales to be bought and sold directly through the
pool and therefore enjoyed high liquidity and price transparency.[66]
Dr Barrie Murray agreed that "it is a delusion to think that
DECC or Ofgem are going to establish an optimal way forward by
tinkering with market" and that much more substantial change
was required.[67]
64. Several independent generators told us that reform
of the wholesale market is necessary to underpin the Government's
objectives. For example, InterGen UK said in their written evidence
that "large-scale reform of the electricity market is required
to support the Government in meeting its long-term three-fold
objective", saying that "action to improve liquidity
is an essential precursor to EMR".[68]
Similarly, ESB International said that "market reform proposals
need to be underpinned by significant improvements in wholesale
market liquidity" and that they "would seek for Government
or Ofgem to publish further thoughts and proposals at the earliest
opportunity".[69]
LIQUIDITY AND THE PROBLEM OF VERTICALLY
INTEGRATED PLAYERS (VIPS)
65. Liquidity is an important feature of a well functioning
market. It is the ability to quickly buy or sell a desired commodity
or financial instrument without causing a significant change in
its price and without incurring significant transaction costs.[70]
A key feature of a liquid market is that it has a large number
of buyers and sellers willing to transact at all times, leading
to a significant volume of individual trades.
66. The current market arrangements have encouraged
the formation of "vertically integrated" companies.
The UK electricity market is dominated by the Big Six vertically
integrated players, which own both generation and supply businesses
and enjoy opportunities to "self-supply" electricity,
bypassing the electricity wholesale market. This has resulted
in low levels of liquidity in the wholesale market because generators
can sign confidential bilateral contracts with retailers outside
the wholesale market. This leads to a lack of reliable price signals,
which deters investments from outside the incumbent Big Six.[71]
67. Many of our witnesses agreed that illiquidity
and the lack of a long-term and transparent reference price was
a barrier to new investment in the electricity sector.[72]
A liquid wholesale market is necessary to allow investors to manage
risk effectively and to reduce the scope for market manipulation.
Transparent prices are needed as a basis for investment decisions,
so that potential entrants can assess opportunities to enter the
market. For International Power, liquidity was a problem "particularly
for less standard products such as peak and off-peak, as these
markets are particularly 'thin'".[73]
Improved price formation and market access were important to independent
generators "looking to 'hedge' output forward at a fair price,
and on timescales that are more consistent with availability of
fuels".[74]
68. We heard that liquidity would have an impact
on the effectiveness of the EMR package and that EMR would affect
liquidity. ESB International suggested that without a liquid and
transparent market, the measures introduced in EMR may not be
effective: "The "FiT with contract for difference"
mechanism that is favoured by Government relies on a transparent
and robust wholesale price, driven by generation cost".[75]
International Power agreed that the Government would need to "ensure
a robust reference price for the CfD FITs mechanism".[76]
Other witnesses emphasised that the EMR proposals would themselves
have a knock-on effect on liquidity. For example, Drax Power told
us that a capacity mechanism could reduce wholesale market liquidity
"as the volume of capacity that is subsidised increases in
a market that already suffers from low liquidity".[77]
69. The lack of liquidity also means that in the
GB market there is only a limited reference price over the longer-term.
In such scenarios, the case for new investment is weakened, because
of a lack of reliable price signals; this can deter new entry
and competition in the sector.[78]
70. The current market arrangements do not facilitate
a fully functioning wholesale electricity market which transmits
the price information necessary to attract investment. We recommend
that the Government incorporate a review of the present trading
arrangements and liquidity in the forthcoming White Paper.
OFGEM'S ROLE IN IMPROVING LIQUIDITY
71. Parliament has delegated responsibility for liquidity
and competitiveness in the electricity market to the regulator,
Ofgem. In this section we consider whether responsibility for
ensuring competitiveness and liquidity is best left to Ofgem.
72. Ofgem has been responsible for promoting competition
in electricity and gas markets since 2000. Since 2009 Ofgem has
been monitoring and investigating the liquidity of wholesale electricity
in Great Britain. It is concerned that the wholesale market is
not delivering the products and signals that all market participants
need to operate their businesses effectively. In particular, independent
suppliers and generators find it difficult to manage risk with
the wholesale products currently available. This could be damaging
the interests of consumers in the supply market, especially if
it means that there is no viable competition for existing suppliers.
73. In its evidence, Ofgem noted some positive signs,
such as through a new trading platform (N2EX) and the efforts
of one of the Big 6 to sell energy "clips" in sizes
more suitable for smaller suppliers. Ofgem believes that that
it is in the best interests of the market to have greater liquidity
and notes that some markets in Europe have achieved greater liquidity
than the UK.[79]
74. Since Ofgem gave evidence to us, it has carried
out substantial work on competition in the wholesale market. On
21 March 2011, Ofgem published the preliminary findings of its
latest Retail Market Review, which found that "further action
is needed to make energy retail markets in Great Britain work
more effectively in the interests of consumers. Consumers are
at risk from a number of features in the market which reduce the
effectiveness of competition".[80]
75. Ofgem was right to tie this work into the EMR
process. Its proposals would require the Big Six to make available
between 10% and 20% of their power generation into the market
through a regular Mandatory Auction.[81]
76. Professor Helm doubted the ability of Ofgem to
change the wholesale market with its current mandate, arguing
that the current arrangements were "part of its institutional
history".[82] He
suggested that the Ofgem Review is an opportunity to change its
culture to reflect the Government's new priorities. We agree that
Ofgem's priorities have been to secure affordability for consumers.
The Ofgem Retail Market Review set out that "Ofgem's principal
objective is to protect the interests of consumers, present and
future, wherever appropriate by promoting effective competition".[83]
It is vital that competition and liquidity are improved to meet
the Government's other objectives of decarbonisation and security
of supply. We believe that measures to improve the market must
be pursued with these other objectives in mind.
77. The Ofgem Review was announced by the Secretary
of State on 27 July 2010 and is exploring whether changes are
needed to the regulatory framework of the electricity market and
to the structure and role of Ofgem. The consultation closed on
24 September 2010 and the Government Response was published on
16 December 2010. The Government's conclusions on the review are
expected to be published in "Spring 2011". The Association
of Electricity Producers told us that the Government's conclusions
should include "clarification of where current Ofgem initiatives
such as Project TransmiT and review of market liquidity would
be relevant to the outcome of these [EMR] reforms".[84]
78. We heard suggestions for ways in which the Government
could act directly to improve liquidity in the electricity market.
Professor Helm reminded the Committee about the relative advantages
of the Pool trading arrangements which, he said, were much better
at delivering a liquid and transparent market than the current
design, explaining that "NETA replaced a compulsory energy
marketyou had to sell into it, and you had to buy out of
it, therefore, by definition, it was liquid and transparentwith
the opposite."[85]
He concluded that "the problem is NETA".[86]
79. We also heard other ways of adapting the market
in order to improve its suitability for increasing amounts of
intermittent generation. For example, Dr Barrie Murray suggested
a development in the role of the System Operator (SO), National
Grid, to manage intermittent supply. He said that National Grid
was "best placed to determine need and should be incentivised
to contract for capacity considering all options including demand
side management and import/export. The SO should also be incentivised
to coordinate wind and marine output forecasting as part of a
centralised management function".[87]
The Welsh Power Group also proposed an extension of the role of
the SO as a central buying agency for more reserve capacity to
balance increasing intermittency.[88]
National Grid agreed that "the mechanisms currently employed
by National Grid as System Operator to procure 'balancing services'
could also be extended or amended to provide additional 'back-up'
capacity".[89]
80. DECC must consider the future evolution of
the electricity wholesale market as part of the Electricity Market
Reform process. The review of Ofgem is an opportunity to ensure
that it delivers decarbonisation and security of supply alongside
affordability for consumers.
81. DECC should investigate the full range of
options for improving liquidity in the wholesale market. DECC
must also consider its options for making the wholesale market
fit for a low-carbon future. We would recommend an evolution of
the System Operator's role and a reform of the "balancing
mechanism".
82. The UK has a significant role in influencing
EU policy and the Government should be ambitious in its decarbonisation
programme to show leadership at the regional level. However, it
is important that UK initiatives should not adversely affect EU
policies. We are concerned that not enough work has been done
to explore these interactions. For example, the European Commission
warned that the UK's proposed carbon price floor risked distorting
price signals given by the EU's cap-and-trade scheme, the EU Emissions
Trading System (EU ETS).[90]
We return to the issue of interactions with EU ETS in chapter
6.
83. National Grid told us that "the EMR project
should fully take into consideration EU objectives and initiatives
such as the development of the internal energy markets (including
the Third [Liberalisation] Package and relevant legislation on
state aid)".[91]
The Third Liberalisation Package is an attempt to promote interaction
between the electricity markets of different EU Member States.
From the UK, this is increasingly possible through electricity
interconnectors, which now link transmission systems across the
seas between the UK, France, Ireland and the Netherlands. National
Grid said that "it will be vital to ensure that interconnection
with Europe is taken into consideration when determining appropriate
generation requirements".[92]
SSE told us that "increased interconnection within the EU
seems inevitable" and suggested that "a range of interconnector
scenarios are tested against the proposed reforms before these
are finalised".[93]
84. The Committee notes that EMR represents a move
to more intervention in electricity markets, away from the trend
of liberalisation in Europea trend that began in the UK.
GE emphasised that the UK has often been a leader in energy market
reform in the EU. GE said that "the current reform process
will be keenly observed in other member states; however, these
benefits will only arise if the UK system has sufficient regulatory
arrangements in place with Europe".[94]
They also told us that "the costs of meeting UK Government
objectives are likely to be significantly reduced over the longer
term if policy objectives are more integrated with the single
European market".[95]
85. The Government must acknowledge the direction
of travel of the electricity market in future, which may well
include increasing interconnection with other European markets.
The Government should explore how this will affect the Electricity
Market Reform package in its White Paper. Electricity Market Reform
needs to be accompanied by a strategic vision of the shape of
the market in coming decades, including the European dimension.
65 Q 90 Back
66
Q 90 Back
67
Ev w1 (Dr Barrie Murray) Back
68
Ev w32 (InterGen UK), section 3.1 Back
69
Ev w19 (ESB International), section 5 Back
70
Ofgem, Liquidity in the GB wholesale energy markets, Discussion
Paper 62/09, June 2009 Back
71
DECC, Electricity Market Reform Consultation Document,
Cm 7983, December 2010, p 32 Back
72
For example, EV W10; Ev w19 (ESB International); Ev 147 (Drax
Power) Back
73
Ev 153 (International Power), section 24 Back
74
Ev 153 (International Power), section 24 Back
75
Ev w19 (ESB International), section 23 Back
76
Ev 153 (International Power), section 23 Back
77
Ev 147 (Drax Power), section 8 Back
78
DECC, Electricity Market Reform Consultation Document,
Cm 7983, December 2010, p 32; Ev 153 (International Power), section
24 Back
79
Ev 177 (Ofgem) Back
80
Ofgem, The Retail Market Review-findings and initial proposals,
21 March 2011 Back
81
Ofgem, The Retail Market Review-findings and initial proposals,
21 March 2011, p 8 Back
82
Q 90 Back
83
Ofgem, The Retail Market Review-findings and initial proposals,
21 March 2011, p 2 Back
84
Ev w23 (AEP), section 18 Back
85
Q 90 Back
86
Q 90 Back
87
Ev w1 (Dr Barrie Murray) Back
88
Ev w26 (Welsh Power Group) Back
89
Ev 187 (National Grid), section 2 Back
90
Point Carbon, "UK carbon floor could distort EUA prices-EC",
Carbon Market News, 25 March 2011 Back
91
Ev 187 (National Grid), section 1 Back
92
Ev 187 (National Grid), section 10 Back
93
Ev 214 (SSE), section 21 Back
94
Ev 208 (GE Energy) Back
95
Ev 208 (GE Energy) Back
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