Overall the UKEB supports the proposals in the Exposure Draft.  However it does express a number of concerns with the proposals namely that:

• The proposed standard should be clarified so that it is explicit that the agreements in the scope of the definition “regulatory agreement” reflects the small subset of regulatory agreements. 
• The proposed standard should be clarified to explicitly exclude certain types of contracts and agreements, such as service concession arrangements.
• The proposed standard should explicitly require an independent third-party as an entity’s regulator. 
• The proposed requirement to exclude regulatory returns relating to assets not yet available for use in Total Allowable Compensation (TAC) does not reflect the substance of that return.

Comments on the draft comment letter are requested by 26 July 2021.  A press release, the draft comment letter and the invitation to comment are available on the UKEB website.