How government is seeking to reduce risk to critical national infrastructure as energy dependency grows
The government will launch a new energy resilience strategy next spring in a bid to reduce the risk of failures that cause social and economic harm.
It announced the strategy on 18 November, highlighting increasing energy demand and dependency across all parts of the economy and society.
The potential fragility of the energy system was highlighted by a major fire on 20 March at National Grid’s North Hyde 275kV substation in west London. It disrupted power to over 70,000 customers, including Heathrow Airport, Hillingdon Hospital, road and rail systems and three data centres. Heathrow was forced to close, with knock-on effects lasting days.
On 18 November the government set out a list of 20 actions it will take over the course of 2026 to minimise the possibility of a repeat, starting with the launch of a new energy resilience strategy in the spring.
The North Hyde substation fire triggered urgent discussion between government, regulators and infrastructure owners about critical national infrastructure (CNI) – assets and systems essential to the functioning of society, the economy and national security.
Traditionally, CNI has been viewed sectorally. The fire showed that CNI is systemic and inter-reliant, with failure in one system rapidly cascading to others.
>> Also read: Chris Glover on how Heathrow’s North Hyde fire exposes hidden vulnerabilities in critical infrastructure
The National Energy System Operator, NESO, called out the lack of attention to connectivity and interdependency between systems in its report on the fire last July, and the government amplified NESO’s concern in its 18 November response.
“NESO’s report made four recommendations to improve the resilience of critical infrastructure to energy disruption through increased understanding of interdependencies between critical energy system assets, the reliance of other CNI sectors on energy supplies, and the risk of disruption to those energy supplies, including what it means to be resilient to that disruption.”
National Energy System Operator’s recommendations
- “Where a CNI or essential service site has multiple supply points connected to the energy system, explicit consideration should be given by the site operator to the level of resilience and operational continuity required, and how this can be achieved.
- “CNI operators should be able to have transparent conversations, then work together with energy networks and system operators to review and establish a mutual understanding of the resilience and security of the energy supply arrangements to the CNI site.
- “NESO and the government should work together to develop an appropriate holistic view of the CNI reliance on the energy system.
- “CNI operators, government and the relevant regulatory bodies should establish a more structured approach to energy resilience, for example via cross-sector partnerships and standards, including standards around continuity of operations under various scenarios.”
In its response, the government noted: “There is currently no cross-sector requirement on CNI operators to ensure specifically the continuity of operations in response to power disruption.”
Government, NESO and regulator Ofgem will do essential groundwork to improve reliability and resilience, so as to prevent a re-run of the chain of events triggered by the North Hyde fire. But the government emphasised that CNI owners and operators must act to protect themselves.
While “overall reliability of supply for the national electricity transmission system was reported as 99.999930% […] no system can be completely immune from disruption.
“Even in a highly resilient energy system, disruptive impacts can still occur and therefore it is important that other sectors take responsibility for their own business continuity in the event of disruption to energy supplies.”
The new energy resilience strategy will set out how government will work with regulators, owners and operators in the energy sector and other CNI to identify and address risks, with a focus on strengthening prevention, preparedness, response and recovery.
New energy resilience strategy commitments
- review and improve asset management arrangements for high voltage substations
- consider the need for independent assurance that critical network assets are being appropriately managed
- review critical customer connections, identify weaknesses, and consider options for improving resilience
- consider and agree risk-based fire standards for high voltage substations
- review the effectiveness of the current Electricity Safety, Quality and Continuity Regulations
- seek to mitigate risk through design across the whole energy system, supported by new specifications and standards if required
- improve liaison with and between emergency responders during significant energy system events
- formalise guidance for escalation and management of significant energy sector incidents
- improve engagement and information sharing between CNI owners and operators to prepare for and respond to incidents
- review existing arrangements and develop industry guidance for restoring customer energy supplies, including CNI, when failures occur
- review legislation to allow for different treatment of electricity customers designated as CNI
- consider the need for an emergency coordinator with powers to take command at a whole energy system level
- publish operational continuity guidelines for CNI, and emphasise the importance of including energy resilience in business continuity plans
- review the methodology used to designate energy assets as CNI
- streamline mapping of dependencies between energy and other CNI
- look at ways to embed power resilience across all CNI sectors
- engage CNI sector regulators on options to incentivise investment in energy resilience
Several of these commitments are already in motion.
The government’s response calls out the need to review the suitability, condition, use and performance of assets in the context of fast changing technologies and demands.
“Our energy system is made up of thousands of assets which were designed and built across many decades. In the intervening period, the number and type of services and sites dependent on those assets have changed,” while energy dependency as increased.
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