Our RIIO-GT3 Business plan sets out how we will secure Britain’s energy now, and in the future, through efficient investment in the National Transmission System (NTS). We are grateful to everyone who took the time to contribute their knowledge and expertise to help shape our plan, which aligns with Ofgem’s four key outcomes for the sector.  

We welcome Ofgem’s recognition of the quality of our Business Plan. Furthermore, we welcome its acknowledgment of the critical role the NTS plays in supporting our country’s energy security, economic prosperity, and clean power ambitions.

We are, however, concerned that Ofgem’s proposed cuts, as they stand, will impair our ability to run a safe, reliable, and resilient network for our customers and the country. Continuing to deliver a network that can secure Britain’s energy today, and in the future, requires targeted investment and a regulatory framework capable of adapting to our fast-evolving energy system.

During the Draft Determination consultation period, our teams have engaged constructively with Ofgem to further demonstrate why investment is needed and what is needed to achieve efficient funding of that investment.  

In our response, we make the following key points:

• Asset health funding: We believe the proposed funding levels are insufficient to stabilise asset failure risk. Investment in asset health is essential to maintain safety and reliability across the network.
• Digital transformation and security: Transforming our IT infrastructure and ensuring the security of our systems and sites remains a top priority. These investments are vital to protect operations and enable smarter, more responsive network management. We do not consider the proposed funding levels to be adequate.  
• Organisational efficiency: We are committed to building a streamlined, future-ready organisation. However, the current incentive framework inhibits the drive for stretch outcomes, ultimately to the detriment of customers.
• Financial framework: While the finance package shows signs of progress, further improvements are needed to support efficient funding. The layering of efficiency challenges has resulted in concerns about long-term affordability and investment viability.  

Our Executive Summary provides a more detailed overview. This covers both our concerns and the other remedies we believe are crucial to protecting the interests of consumers and the nation’s energy security now, and in the future, and which is consistent with Ofgem's regulatory and statutory duties.

Looking ahead:

We remain committed to working collaboratively with Ofgem and the wider industry to ensure the Final Determination on our RIIO-GT3 Business Plan, expected in December, supports a resilient, secure, and efficient gas transmission system. Our focus is on delivering value for our customers, while enabling the infrastructure needed for Britain’s energy transition.

You can view our published documents, including our Executive Summary here > DD - Published documents.