Consultation response
Response to Ofgem’s Curate consultation: Demand Connections Reform
Curate proposes a commitment fee for data centre projects of 40 MW and above, together with queue management milestones and evidence of financial capability. I support the fee, its 2.5 to 7.5 per cent range and the 40 MW threshold. My central point is that the fee may be secured by a bond or letter of credit, so as drafted it tests access to credit rather than project viability. A well-capitalised group can hold a speculative position cheaply, while a viable but thinly capitalised project may not. Neither the self-declaration route nor the credit support rules require anyone to establish who ultimately stands behind a commitment. I propose a stated standard for identifying the ultimate controlling party, using Companies House data that is already public.
Other points in the response
The fee threshold is defined in the drafted code as connection capacity, but the consultation narrative describes it in rated IT load. The two differ once cooling and redundancy are counted, and the drafted code should govern.
The queue management milestones are consulted on at 10 MW rated IT load. The drafted definition of a Data Centre Service keeps 10 MW only for enterprise facilities. For colocation, and for any facility serving third-party customers, the drafted threshold is 1 MW.
Ireland is the closest comparator to Great Britain and is not analysed. The Commission for Regulation of Utilities decision of December 2025 attaches conditions to the connection itself and uses no commitment fee. I asked whether that approach was considered.
Ofgem’s own figures show reformed securities averaging 0.2 per cent of capital expenditure. That comparison does more to justify the fee range than the IRR case study does.
- ConsultationOfgem, Curate: Demand Connections Reform (proposed data centre connection reforms)
- Published29 July 2026
- Closed17 September 2026
- Response submitted6 September 2026, on Ofgem’s response template
Download the full response (PDF, 25 pages)
The text is as submitted. Telephone number and email address have been removed from this copy. Ofgem’s consultation page
