Consultation Submissions

In response to Ofgem's call for input on affordability and debt in the domestic retail market, we highlight that debt is increasing not diminishing. We propose solutions, but stress that we face an enduring problem of energy poverty and debt that existed long before the energy and cost of living crises. A whole-system joined up approach is needed to deliver affordable energy for all.

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The REMA options being considered represent not just potential opportunity for consumers but also many potential risks. In this consultation we continue to urge DESNZ, Ofgem and the NESO to ensure fair outcomes for end-users.

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DESNZ call for evidence on default energy tariffs is an important step in consumer-led demand. We are supportive of principles to enable fair default tariffs from suppliers for different household segments. But first DESNZ and Ofgem must fix wider challenges in retail markets including affordability and debt problems experienced by a high proportion of energy customers; flaws in the price cap and smart meter roll-out; consumer protection and the uptake of low carbon technologies, such as electric vehicles. 

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Ofgem is consulting on its methodology for the next network price control RIIO3. We welcome the focus on the investment needed to meet Net Zero but urge Ofgem to emphasise the companies' own environmental impacts in areas like SF6 emissions, energy losses and methane leakage. We also highlight the need for wider engagement on the difficult inter-generational questions around the future of the gas networks.

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Economic regulation is taking place in a changing enviroment. The need for utilities to deliver reliance against weather and other shocks, in the face of climate change both have an impact. In this consultation response, we ask how regulators can move to a far wider question about the role of data and we urge for greater engagement with current and future consumers.

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In our consultation submission, we argue that wholescale changes to the legislation that defines regulator's objectives is not needed. But there is an urgent need for re-examination of regulatory frameworks and capabilities in the face of machine learning/AI as well as regarding adaptation to climate change. Moreover, we think the right balance is not being struck between regulators' responsibilities and government's

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