legal and safety (cv14)

Legal and Safety (CV14) ED2 Engineering Justification Paper

ED2-NLR(A)-SPEN-001-SAF-EJP

Issue Date Comments

Issue 0.1 March 2021 Issued for SRG

Issue 0.2 April 2021 Revised to incorporate review comments

Issue 1 30th June 2021 Draft Submission

Issue 2 30th November 2021 Final Submission

Scheme Name RIIO-ED2 – CV14 – Legal and Safety

PCFM Cost Type Non-Load Related – Other

Activity Legal and Safety

Primary Investment Driver

Regulatory and legal responsibilities to manage and operate a safe network

Reference ED2-NLR(A)-SPEN-001-SAF-EJP

Output Type Legal and Safety

Cost SPD £4.715m SPM £4.385m

Delivery Year 2023-2028

Reporting Table CV14

Outputs included in ED1 Yes/No

Business Plan Section Ensure a Safe and Reliable Electricity Supply

Primary Annex Annex 4A.18: Legal and Safety (CV14) Strategy

Spend Apportionment ED1 ED2 ED3

£m £9.100m £m

ED2-NLR(A)-SPEN-001-SAF-EJP – CV14 Legal and Safety

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Technical Governance Process

Project Scope Development IP1(S)

To be completed by the Service Provider or Asset Management. The completed form, together with an accompanying report, should be endorsed by the appropriate sponsor and submitted for approval.

IP1 – To request project inclusion in the investment plan and to undertake project design work or request a modification to an existing project IP1(S) – Confirms project need case and provides an initial view of the Project Scope IP2 – Technical/Engineering approval for major system projects by the System Review Group (SRG)

IP2(C) – a Codicil or Supplement to a related IP2 paper. Commonly used where approval is required at more than one SRG, typically connection projects which require connection works at differing voltage levels and when those differing voltage levels are governed by two separate System Review Groups. IP2(R) – Restricted Technical/Engineering approval for projects such as asset refurbishment or replacement projects which are essentially on a like-for-like basis and not

requiring a full IP2 IP3 – Financial Authorisation document (for schemes > £100k prime) IP4 – Application for variation of project due to change in cost or scope

PART A – PROJECT INFORMATION

Project Title: RIIO ED2- CV14 – Legal and Safety

Project Reference: ED2-NLR(A)-SPEN-001-SAF-EJP

Decision Required: To give concept approval for the CV14 – Legal & Safety Strategy within the RIIO-

ED2 price control period.

Summary of Business Need:

SP Distribution (SPD) and SP Manweb (SPM) have regulatory and legal responsibilities to manage and operate a safe

network. This includes responsibilities as a building and asset owners and employer for workplace safety. This paper

specifically covers the engineering justification for our RIIO-ED2 proposals in Asbestos Management, Metal Theft, Earthing

Upgrades and Safety Recreational Sites.

Summary of Project Scope, Change in Scope or Change in Timing:

SP Energy Networks shall undertake programmes of work to manage the risk and legal responsibilities relating to asbestos

management, metal theft, earthing upgrades and safety recreational sites across our SPD and SPM license areas.

Expenditure Forecast (in 2020/21 Prices)

Recommended Scheme Investment Profile Total

(£m)

Incidence (£m)

2023/24 2024/25 2025/26 2026/27 2027/28

CV14 – Asbestos Management – Surveys and

Signage (SPM) 1.015 0.203 0.203 0.203 0.203 0.203

CV14 – Asbestos Management – Containment or

Removal (SPM) 0.634 0.127 0.127 0.127 0.127 0.127

CV14 – Metal Theft (SPM) 0.529 0.106 0.106 0.106 0.106 0.106

CV14 – Earthing Upgrades (SPM) 1.205 0.241 0.241 0.241 0.241 0.241

CV14 – Safety Recreational Sites (SPM) 0.893 0.179 0.179 0.179 0.179 0.179

CV14 – Associated Pension Costs (SPM) 0.109 0.023 0.022 0.022 0.022 0.020

SPM Subtotal 4.385

CV14 – Asbestos Management – Surveys and

Signage (SPD) 0.953 0.191 0.191 0.191 0.191 0.191

CV14 – Asbestos Management – Containment or

Removal (SPD) 0.634 0.127 0.127 0.127 0.127 0.127

CV14 – Metal Theft (SPD) 0.409 0.082 0.082 0.082 0.082 0.082


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CV14 – Earthing Upgrades (SPD) 1.503 0.301 0.301 0.301 0.301 0.301

CV14 – Safety Recreational Sites (SPD) 1.132 0.226 0.226 0.226 0.226 0.226

CV14 – Associated Pension Costs (SPD) 0.084 0.018 0.017 0.017 0.017 0.015

SPD Subtotal 4.715

This Proposal 9.100

PART B – PROJECT SUBMISSION

Proposed by David Cupples / Charlie Dodds Signature Date: 30/11/2021

Endorsed by Matthew Jones Signature Date: 30/11/2021

PART C – PROJECT APPROVAL

Approved by Malcolm Bebbington Signature

Date: 30/11/2021


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1. Contents 2. Introduction ........................................................................................................................................................ 4

3. Background Information .................................................................................................................................. 4

4. Needs Case ....................................................................................................................................................... 11

5. Optioneering .................................................................................................................................................... 12

6. Detailed Analysis .............................................................................................................................................. 13

7. Deliverability and Risk .................................................................................................................................... 14

8. Future Pathways – Net Zero ........................................................................................................................ 18

9. Conclusion ........................................................................................................................................................ 19


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2. Introduction This paper covers the proposed activity in RIIO-ED2 relating to CV14 Legal and Safety that are not

covered in individual EJPs. The workstreams included are;

• Asbestos Management

• Metal Theft

• Earthing Upgrades

• Safety Recreational Sites

The following legal and safety workstreams are not included with this paper and are covered in

standalone or associated EJPs;

• Site Security (ED2-NLR(A)-SPEN-002-SAF-EJP)

• Fire Protection (ED2-NLR(A)-SPEN-003-SAF-EJP)

• Fire Blankets (Included within ED2-NLR(A)-SPEN-001-SWG-EJP)

• Shallow Cables (Weaver Sluices)( ED2-NLR(A)-SPM-002-SAF-EJP)

SP Distribution (SPD) and SP Manweb (SPM) have regulatory and legal responsibilities to manage and

operate a safe network. This includes responsibilities as a building and asset owners and employer

for workplace safety. This paper specifically covers the engineering justification for our RIIO-ED2

proposals in Asbestos Management, Metal Theft, Earthing Upgrades and Safety Recreational Sites.

The timing of investment proposed within this paper ensures SP Energy Networks continues to

meet its regulatory and legal responsibilities to manage and operate a safe and resilient network.

This investment is spread

3. Background Information

3.1. Asbestos Management

Regulatory Requirements The Control of Asbestos Regulations 2012 (CAR 2012), Part 2, Regulation 4, places a legal duty on

SP Distribution and SP Manweb to manage asbestos within the sites and buildings within our

network. The Health and Safety Executive have published an Approved Code of Practice (ACoP) -

L143 ‘managing and working with asbestos’ which provides guidance for duty holders on complying

with CAR 2012.

CAR 2012 sets out the responsibility of SPD and SPM to carry out assessment of all premises to

determine the presence of asbestos, and duty to manage the risk associated where asbestos is

identified.

SP Energy Networks Strategy SP Energy Networks’ Asbestos Management Strategy, SMS-11-013 Issue No.7, describes the overall

management strategy and defines the minimum standards required to be implemented for the

management of asbestos containing materials (ACMs) in network premises and assets.

The Management Strategy is built around 10 ‘Minimum Standards’ that are applied to ensure

compliance with the legal duty and safety of all who may come into contact with our premises or

assets.


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These standards are as followings

• Minimum Standard 1 – Locating and Recording the Condition of ACMs.

• Minimum Standard 2 – Identification of the Location of ACMs.

• Minimum Standard 3 – Information, Instruction and Training.

• Minimum Standard 4 – Monitoring the Condition of Identified ACMs.

• Minimum Standard 5 – Assessment of Asbestos Work

• Minimum Standard 7 – Notifiable Non-Licensed Work

• Minimum Standard 8 – Non-Licensed Work

• Minimum Standard 9 – Monitoring Asbestos Removal Works

• Minimum Standard 10 – Emergency Procedure

RIIO-ED1 Activity Within RIIO-ED1 we have an ongoing asbestos management programme to keep our records on

ACMs within our network assets up to date and manage the removal / containment / disposal of

asbestos where necessary. SP Energy Networks have a management survey report for every

substation location and as part of our management programme undertake review inspections of all

sites where ACMs have been identified. The frequency of re-inspection is based on risk rating from

the inspection reports as outlined in Table 1 below and set out in SMS-11-013.

Health Index (Report Rating) Re-Inspection Timescale (years)

5 High 10-12 0.5

4 Medium 7-9 1

3 Low 5-6 4

2/1 Very Low 2-4 8 Table 1- Asbestos Re-Inspection Timescales

Where re-inspection identifies issues relating to the condition of ACMs and the associated risk is

above acceptable limits intervention is undertaken. Interventions may include but not limited to the

following;

• Installation of asbestos signage.

• Containment of asbestos at location to reduce risk.

• Removal and disposal of asbestos in line with appropriate regulations.

• Clean-up and disposal of loose asbestos in line with appropriate regulations.

• Testing of suspected ACMs and air testing where necessary.

All works are carried out by licensed asbestos contractors where required and waste disposed in

accordance with current hazardous waste regulations.

Figure 1 and Figure 2 below provided a summary view of performance to date within RIIO-ED1,

forecast cost and volumes for the remaining 2 years, and forecast cost and volumes for the RIIO-

ED2 preferred option for asbestos management detailed within this paper


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Figure 1- Summary of SPM ED1 to ED2 CV14 Asbestos Management

Figure 2 - Summary of SPD ED1 to ED2 CV14 Asbestos Management

Costs and volumes relating to asbestos management works being undertaken at Frodsham and

Rainhill 132kV Substations are set out in ED2-NLR(A)-SPM-001-CIV-EJP and are excluded from this

paper.

3.2. Metal Theft

Regulatory Requirements The Electricity Safety, Quality and Continuity Regulations 2002 (ESQCR) Part 2 (6) states “A

generator or distributor shall be responsible for the application of such protective devices to his

network as will, so far as is reasonably practicable, prevent any current, including any leakage to

earth, from flowing in any part of his network for such a period that that part of his network can no

longer carry that current without danger”. Metal theft on the network is predominantly linked to the

copper tape and cable used for earthing purposes at our substation sites and when stolen can leave

the network assets in an unsafe condition. Therefore, under ESQCR requirements SPD and SPM

must undertake action to remediate following metal theft and where necessary undertake actions to

prevent further metal theft.


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RIIO-ED1 Activity Within the RIIO-ED1 price control period to date metal theft has seen a marked reduction in

intervention requirements from that of DPCR5. Table 2 below outlines the RIIO-ED1 intervention

rate to date. The majority of interventions have been undertaken at our substations sites, with the

most common being the replacement of stolen copper earthing.

License DPCR5 RIIO-ED1

10/11

(No)

11/12

(No)

12/13

(No)

13/14

(No)

14/15

(No)

15/16

(No)

16/17

(No)

17/18

(No)

18/19

(No)

19/20

(No)

20/21

(No)

SPM - 462 200 95 262 98 372 61 49 35 17

SPD - 297 242 392 219 128 31 46 38 17 19

Table 2 - Summary of Metal Theft Interventions in DPCR5 & RIIO-ED1

Within RIIO-ED1 there is an ongoing programme to roll out the use of Smart locks on our

substation sites within the SPM area. This has been credited with assisting reducing the number of

metal theft incident in the SPM area linked to unauthorised access using stolen or copied keys. It is

expected that the smart lock rollout will be completed across both SPD and SPM areas over RIIO-

ED1 and RIIO-ED2.



ED2 preferred option for metal theft detailed within this paper

Figure 3 - Summary of SPM ED1 to ED2 CV14 Metal Theft


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Figure 4 - Summary of SPD ED1 to ED2 CV14 Metal Theft

3.3. Earthing Upgrades

Regulatory Requirements The upgrading of earthing at secondary substations ensures the SP Energy networks is compliant

with national and international standards as well statutory legislation and licence requirements. The

Technical specification for earthing and bonding at secondary substations is aligned with the current

releases of ESQC Regulations, BS EN50522, ENA TS 41-24 and ENA EREC S34.

SP Energy Network’s Policy The publication of the Technical specification for earthing and bonding at secondary substations

EART-03-003 in February 2020 is to be complied with for all new installations and where significant

work is being undertaken on that substation or asset in terms of pole mounted equipment this is

when the pole is being replaced but the plant is still in good fit for purpose condition.

In the case of Pole mounted substations, the separation is from the HV earthing system and the LV

Neutral earth is now set at a minimum of 20m, as shown in Figure 5 below, this is completed when

the PM transformers is replaced and covered under the asset replacement unit cost.


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Figure 5 - Pole Mounted S/S Earthing Diagram

RIIO-ED1 Activity SP Energy Network’s substation earthing policy (EART-03-003) was updated in February 2020 to

take account of the latest standards as set out in Section 3.3.1. As a result, no programme of

standalone earthing upgrade works have been undertaken within RIIO-ED1, although sites where

asset replacement has taken place all new assets are installed to current policy.



ED2 preferred option for earthing upgrade detailed within this paper

Figure 6 - Summary of SPM ED1 to ED2 CV14 Earthing Upgrade


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Figure 7- Summary of SPD ED1 to ED2 CV14 Earthing Upgrade

3.4. Safety Recreational Sites

Regulatory Requirements As a responsible network operator, the requirement to maintain a safe and secure network is a key

deliverable and as such during the RIIO-ED2 period we will as part of the OHL modernisation

program, to design solution that will reduce the risk caused by our overhead apparatus that crosses

or is in proximity of recreational sites.

SP Energy Network’s Policy A recreational site is defined within SP Energy Network’s Asset Inspection and Condition

Assessment Policy Asset-01-021 as follows;

“For the purposes of this policy, the term recreational area is defined as areas used by members of

the public for leisure or recreational activities, where their normal/expected activities may increase

the risk of contact with live conductors.”

The risk classification for poles located in or in the vicinity of a recreational area/site are Higher than

Normal Risk.

RIIO-ED1 Activity Following programmes of intervention at recreational sites in both SPD and SPM, undertaken in

DPCR5, relatively low volumes of intervention have been progressed within RIIO-ED1 price control

to date. Figure 8 and Figure 9 below provided a summary view of performance to date within RIIO-

ED1, forecast cost and volumes for the remaining 2 years, and forecast cost and volumes for the

RIIO-ED2 preferred option for safety recreational sites detailed within this paper.


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Figure 8 - Summary of SPM ED1 to ED2 CV14 Safety Recreational Sites

Figure 9 - Summary of SPD ED1 to ED2 CV14 Safety Recreational Sites

4. Needs Case

4.1. Asbestos Management Within SPD and SPM licence areas, the electricity network and substations were first constructed in

the 1930s, with major expansion of the network in the 1960s and 1970s when asbestos was in

regular use in the construction and electrical plant industry due to its fire-resistant properties.

Therefore, ACMs likely to be present in proportion of our substations and assets.

As we continue to modernise our network and replace or refurbish substations and assets, SP

Energy Networks are dutybound to manage the risk from asbestos. A programme of ongoing

inspections, surveys and testing are required to facilitate proposed works within RIIO-ED2 as well as

ongoing maintenance of the networks assets.

Two named projects are being undertaken at Frodsham 132kV and Rainhill 132kV indoor

substations which include CV14 Asbestos Management expenditure. The associated costs are not

included within this paper. For details in relation to these projects please refer to the project specific

EJP ED2-NLR(A)-SPM-001-CIV-EJP.


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It is expected that during RIIO-ED2 the ongoing programme for Asbestos Management shall

continue.

4.2. Metal Theft Metal theft continues to be an issue although incident numbers have fallen in recent years. The rate

of metal theft incidents can be impacted by external factors including scrap metal price. It is

therefore necessary for SPD and SPM to have a reactive policy in place to undertake repairs to the

network whenever metal theft occurs. This ensures SPD and SPM comply with ESQCR

requirements in relation to maintaining a safe network.

4.3. Earthing Upgrades The requirement to undertake Earthing upgrades is to mitigate against high Earth Potential Rise

(EPR) or step and touch potential. The SP Energy Networks Secondary Substation Earthing policy

EART-03-003 Issue 01 that sets out the new separation between earthing systems for pole mounted

and ground mounted substation. This policy demonstrates compliance with the latest national and

international standards.

4.4. Safety Recreational Sites The protection of the public from the inadvertent contact with overhead lines and recreational sites

such as fishing sites, caravan/ camping sites, etc is a key public concern and as such we are required

to reduce this risk by employing suitable solutions/designs. As a responsible network operator SP

Energy Networks attribute greater risk to sites where overhead lines cross or are in the vicinity of

land used for recreational purposes. Therefore, intervention is required at recreational sites where

the risk is perceived to be greater than acceptable to reduce the risk level as far as reasonably

practicable.

5. Optioneering Option 2 as set out below is deemed the “do minimum” activity required by SP Energy Networks to

ensure compliance with regulatory and legislative requirement across our SP Distribution and SP

Manweb license areas.

Option Status Comments

1 Do Nothing Rejected This option would result in SPD and SPM not

complying with current regulatory requirements

and legislation. Therefore, this option was

rejected.

2 Undertake Legal and Safety

Programmes to meet Legal

Requirements

Adopted This is deemed as the “do minimum” option.

Table 3 - Investment Options


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6. Detailed Analysis

6.1. Option 2 – Undertake Legal and Safety Programmes to meet legal

requirements (Do minimum Option)

Asbestos Management This option consists of undertaking the necessary inspection, testing and actions to manage the risk

of asbestos within our asset base. This shall be carried out in accordance with our Asbestos

Management Strategy SMS-11-013 ensuring compliance with CAR 2012.

Metal Theft This option entails the continuation of a reactive programme to rectify damage and replace stolen

assets to substations and plant following metal theft incidents.

Earthing Upgrades Earthing upgrades will be identified on a scheme by scheme basis as part of the modernisation

design, and as part of the asset replacement program for ground mounted substations where the

asset requiring the earthing upgrades is not being replaced under CV7, but other works are being

undertaken

Safety Recreational Sites The options for each recreational site differ due to the voltage and the complexity of the design

required to reduce or remove the risk completely however the design is required to ensure that SP

Energy Networks operates a safe overhead network and as such when modernisation of the

overhead line is due we will as part of that overall design look to reduce this risk.

6.2. Options Technical Summary Table # Option Technical Summary

2 Undertake Legal and

Safety Programmes to

meet legal requirements

SP Energy Networks shall undertake programmes of work to manage

the risk and legal responsibilities relating to asbestos management,

metal theft, earthing upgrades and safety recreational sites across our

SPD and SPM license areas.

Table 4 - Options Technical Summary

6.3. Options Cost Summary Table Table 5 below outlines the costs associated with option considered.

Option CV Cost Breakdown RIIO ED2

Total (£m)

Option 2

(Adopted)

CV14 Asbestos Management – Surveys and Signage (SPM) 1.015

CV14 Asbestos Management – Containment or Removal (SPM) 0.634

CV14 Metal Theft (SPM) 0.529

CV14 Earthing Upgrades (SPM) 1.205

CV14 Safety Recreational Sites (SPM) 0.893

CV14 Associated Pension Costs (SPM) 0.109

SPM TOTAL 4.385

CV14 Asbestos Management – Surveys and Signage (SPD) 0.953

CV14 Asbestos Management – Containment or Removal (SPD) 0.634

CV14 Metal Theft (SPD) 0.409


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Option CV Cost Breakdown RIIO ED2

Total (£m)

CV14 Earthing Upgrades (SPD) 1.503

CV14 Safety Recreational Sites (SPD) 1.132

CV14 Associated Pension Costs 0.084

SPD TOTAL 4.715 Table 5 - Cost Summary Table

Asbestos Management The unit costs and volumes for Asbestos Management are based on the ongoing RIIO-ED1 asbestos

management programme and latest available 2020/21 framework prices.

Metal Theft The unit costs for metal theft interventions within ED2 were developed from an assessment of the

average expenditure per intervention to date in RIIO-ED1 revised to 2020/21 price base. Predicted

volumes for metal theft interventions within RIIO-ED2 have been based on the average of the most

recent years reported volumes within RIIO-ED1.

Earthing Upgrades The unit costs for the earthing upgrades are based on the current wood Pole OHL framework

contract using an average length of earthing required to achieve the required resistive value and the

separation between earthing systems. Table 1Table 6 below provides a breakdown of the unit costs

for earthing upgrades.

Earthing Upgrades Unit Cost

OHL LV Earthing £683.34

OHL HV Earthing £292.86

Total Unit cost for OHL Earthing £976.20

GM Substation Earthing Unit Cost* £3796.69 *Unit cost has been extracted from GM Substation Unit Costs. Refer to Annex 5A.5 Unit Cost Manual.

Table 6 - Earthing Upgrades Unit Costs Summary

Safety Recreational sites The unit costs calculation for recreational sites was based on the previous costs delivered over the

last 2 price reviews, the unit costs varies from site to site due to the complexity of the solution and

as such the variance in the costs is significant.

7. Deliverability and Risk

7.1. Preferred Option The preferred option for Legal and Safety in RIIO-ED2 is Option 2 and shall be to undertake the

following programmes of work;

• Continuation of Asbestos Management in line with Strategy SMS-11-013,

• Continuation of our reactive programme where incidents of metal theft occur on the

network,


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• Carry out a targeted programme of earthing upgrade on assets where other works are being

undertaken in RIIO-ED2, that do not include asset replacement, to comply with current

standards,

• Programme of works to reduce or remove the risk from live overhead conductors at

locations identified as recreational sites.

7.2. Sensitivity of Preferred Option The costs used to drive the programmes within this paper are based on actuals and frameworks unit

costs for the works forecast within RIIO-ED2. In addition, the programmes are required works to

comply with legal and regulatory requirements and there are no other alternative options available.

Therefore, no additional sensitivity analysis was undertaken and no impact to the proposed option.

7.3. Expenditure & Delivery Profile The total proposed expenditure of £9.100m across RIIO-ED2 is presented in Table 7 below

followed by the delivery profile volumes in Table 8. The delivery profile is consistent across all 5

years of RIIO-ED2. Note that costs relating to the named projects at Frodsham 132kV and Rainhill

132kV Substations are not included within this paper and can be found in the dedicated EJP (EJP

ED2-NLR(A)-SPM-001-CIV-EJP)

CV Activity 23/24

(£m)

24/25

(£m)

25/26

(£m)

26/27

(£m)

27/28

(£m)

Total

(£m)

SPM CV14 Asbestos Management – Surveys and Signage 0.203 0.203 0.203 0.203 0.203 1.015

SPM CV14 Asbestos Management – Containment or Removal 0.127 0.127 0.127 0.127 0.127 0.634

SPM CV14 Metal Theft 0.106 0.106 0.106 0.106 0.106 0.529

SPM CV14 Earthing Upgrades 0.241 0.241 0.241 0.241 0.241 1.205

SPM CV14 Safety Recreational Sites 0.179 0.179 0.179 0.179 0.179 0.893

SPM CV14 Associated Pension Costs 0.023 0.022 0.022 0.022 0.020 0.109

SPD CV14 Asbestos Management – Surveys and Signage 0.191 0.191 0.191 0.191 0.191 0.953

SPD CV14 Asbestos Management – Containment or Removal 0.127 0.127 0.127 0.127 0.127 0.634

SPD CV14 Metal Theft 0.082 0.082 0.082 0.082 0.082 0.409

SPD CV14 Earthing Upgrades 0.301 0.301 0.301 0.301 0.301 1.503

SPD CV14 Safety Recreational Sites 0.226 0.226 0.226 0.226 0.226 1.132

SPD CV14 Associated Pension Costs 0.018 0.017 0.017 0.017 0.015 0.084

Table 7 - Summary of Expenditure Profile


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CV Activity 23/24

(Vol)

24/25

(Vol)

25/26

(Vol)

26/27

(Vol)

27/28

(Vol)

Total

(Vol)

SPM CV14 Asbestos Management – Surveys and Signage 684 684 684 684 684 3420

SPM CV14 Asbestos Management – Containment or Removal 18 18 18 18 18 90

SPM CV14 Metal Theft 42 42 42 42 42 210

SPM CV14 Earthing Upgrades 101 101 101 101 101 505

SPM CV14 Safety Recreational Sites 7 7 7 7 7 35

SPD CV14 Asbestos Management – Surveys and Signage 469 469 469 469 469 2345

SPD CV14 Asbestos Management – Containment or Removal 18 18 18 18 18 90

SPD CV14 Metal Theft 28 28 28 28 28 140

SPD CV14 Earthing Upgrades 126 126 126 126 126 630

SPD CV14 Safety Recreational Sites 9 9 9 9 9 45

Table 8 - Summary of Delivery Profile

7.4. SP Manweb Company Specific Factors As a result of the unique interconnected design of our network within SP Manweb license area costs

relating to CV14 – Asbestos Management works have been accounted for within our company

specific factors. It has been determined that £0.20m of our CV14 – Asbestos Management and

associated volumes, are as a result of the SP Manweb network design. Refer to Annex 4A.25 - SP

Manweb Company Specific Factors for further details.

7.5. Risk Our Asbestos Management Programme is the continuation of RIIO-ED1 with similar volumes being

delivered. These are delivered using our framework licensed asbestos contractors to carry out our

surveys and containment or removal works. Therefore, we see no risk to the deliverability of our

asbestos programme.

Metal Theft is a reactive strategy and reliant on the number of incidents that occur. Given the RIIO-

ED2 forecast and recent trends are significantly lower than that delivered in early RIIO-ED1. There

remains a risk that fluctuations in incidents year on year will mean delivery may vary from the

current forecast however we believe this is manageable within our forecast plan.

Our Earthing Upgrade interventions within RIIO-ED2 shall be delivered alongside our asset

modernisation programmes utilising the same contractors and resource. There is a need to manage

and assess the land and planning rights associated with additional earthing, this will become more

demanding under the new standards. We will keep this risk under ongoing review.

Safety recreational sites is a relatively low volume programme of work in comparison to our wider

overhead line strategies within RIIO-ED2. Therefore, we foresee no risks in the deliverability of this

programme outside the site-specific solutions varying.

7.6. Stakeholder Engagement Robust stakeholder engagement has been completed to identify what is important for customers in

RIIO-ED2, and to gain insights from key stakeholders such as manufacturers, community energy

groups, water and transportation companies, business groups, academia and asset managers from a


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range of industry. This ensures that the views and needs of all key stakeholders, as well as customer

acceptability, are reflected in the proposed costs and volumes in this paper.

Below is a summary of key relevant outcomes from stakeholder engagement for this programme of

works. The views of the stakeholders can be explored in more detail in Annex 3.1: Co-creating our

RIIO-ED2 business plan with our stakeholders, and in Annex 4A.18: Legal and Safety (CV14)

Strategy.

Customer Feedback

• “How SPEN manages health and safety regulation" was ranked 5/24 and 4/24 by domestic

and commercial customers respectively. – Reliability Triangulation C1.2

• The majority of domestic customers (72%) agree SPEN should continue to proactively invest

to resolve potential safety risks and perceive it as an 'inbuilt' responsibility that SPEN have.

The majority of customers are also happy to accept a bill increase if it is necessary to keep

the network safe. – Reliability Triangulation C2.14

Investing in Legal and Safety programmes of work within this paper support this by ensuring our

network assets are in a safe and compliant condition.

Manufacturers

• Manufacturers provided the following views:

o Modernisation is essential to ensuring network resilience;

o Given customers’ increasing reliance on electricity, it is important to have a focus on

reducing fault rates as well as reducing the extent of impact of faults on customers;

o Increasing grid dynamic response capabilities has allowed many utilities worldwide to

improve existing infrastructure performance and quality of supply.

This programme of works will improve network resilience / reduce the impact of faults / improve

network dynamic operability by upgrading our assets to ensure compliance with latest regulations

and replacing damaged / stolen earthing while supporting overall resilience of the network.

Energy Consultants

• Energy consultants agreed that SP Energy Networks should continue to utilise proven

interventions on network assets, and there has been clear support for SP Energy Networks

to continue investing in network resilience [to reduce faults].

This EJP sets out a range of proven interventions including through all the programmes within this

paper. SP Energy Networks have also sought to adopt proven innovative alternatives wherever

possible and provide cost-efficiency.

Local Governments

• Local governments agreed with SP Energy Networks’ approach of managing risk by focusing

on replacing and modernising the poorest condition & highest risk assets.

This paper sets out how SP Energy Networks are intervening, across a number of programmes, on

our poorest condition and highest risk assets.


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8. Future Pathways – Net Zero

8.1. Primary Economic Driver The key driver for this proposal is to ensure compliant with legal obligations and managing safety risk

from the network.

8.2. Pathways and End Points Carrying out the legal and safety activities detailed within this paper are a necessary requirement to

maintain the safety, resilience and reliability of the distribution network under all decarbonisation

pathways. As society continues to decarbonise and the role of the network becomes more critical

to customers, it is increasingly critical that fire safety of our network is maintained and improved.

8.3. Asset Stranding Risks There is not considered to be any asset stranding risk associated with this programme. All Primary

and Grid sites are intended to be occupied for the forecast asset life.

8.4. Losses / Sensitivity to Carbon Prices It has not been necessary to consider losses of carbon pricing as part of this investment programme.

8.5. Future Asset Utilisation The works being carried out in relation to asbestos removal and earthing upgrade are ensuring that

these areas of the Network are fit for future use / repowering.

8.6. Whole Systems Benefits Whole system solutions have been considered as part of this proposal. No alternatives have been

identified that could be provided through a whole systems solution. The completion of this scheme

will maintain the integrity of the distribution network and its enduring ability to facilitate wider

whole system benefits.

8.7. Environment and Sustainability

Operational and embodied carbon emissions The Legal and Safety programme has the potential to result in embodied carbon from the delivery of

interventions required. There is unlikely to be any impact on SPEN’s Business Carbon Footprint

(BCF).

Supply chain sustainability For us to take full account of the sustainability impacts associated of the Legal and Safety

programme, we need access to reliable data from our suppliers. The need for carbon and other

sustainability credentials to be provided now forms part of our wider sustainable procurement

policy.

Resource use and waste Potential interventions may result in the consumption of resources and the generation of waste

materials.

Where waste is produced it will be managed in accordance with the waste hierarchy which ranks

waste management options according to what is best for the environment. The waste hierarchy gives


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top priority to preventing waste in the first instance, then preparing for re-use, recycling, recovery,

and last of all disposal (e.g. landfill).

Biodiversity / natural capital Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to biodiversity and natural capital.

Preventing pollution Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to pollution. However, SPEN will always follow all relevant waste regulations and will make

sure that special (hazardous) waste produced or handled by our business including asbestos is

treated in such a way as to minimise any effects on the environment.

Visual amenity Due to the nature of the proposed interventions, it is unlikely that there will be any impact in

relation to visual amenity.

Climate change resilience Due to the nature of the proposed interventions, it is unlikely that there will be any impacts in

relation to future changes in climate.

9. Conclusion SPD and SPM propose to undertake programmes of work within RIIO-ED2 price control period to

manage legal responsibilities and safety risks relating to asbestos management, metal theft, earthing

standards and recreational sites. Most of these programmes are continuing from established RIIO-

ED1 works apart from Earthing Upgrades, where a change in standards is driving a step change in the

level of work at HV ground and pole mounted substations.

Predicted costs: £ 9.100m (£4.385m – SPM, £4.715m - SPD)

• Timing of investment: 2023 – 2028

• Volumes: 7510 (4260No SPM, 3250 No SPD)

CV Activity Total (£m)

SPM CV14 Asbestos Management – Surveys and Signage 1.015

SPM CV14 Asbestos Management – Containment or Removal 0.634

SPM CV14 Metal Theft 0.529

SPM CV14 Earthing Upgrades 1.205

SPM CV14 Safety Recreational Sites 0.893

SPM CV14 Associated Pension Costs 0.109

SPD CV14 Asbestos Management – Surveys and Signage 0.953

SPD CV14 Asbestos Management – Containment or Removal 0.634

SPD CV14 Metal Theft 0.409

SPD CV14 Earthing Upgrades 1.503

SPD CV14 Safety Recreational Sites 1.132

SPD CV14 Associated Pension Costs 0.084


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legal and safety (cv14)

Documents