Consultation Submissions

Consultation Submissions

In this submission, we make high-level comments on locational pricing - in particular on the customer impacts and fairness and on scope and sequencing - before turning to specific questions Ofgem has raised. We argue that the underlying charging structures need to send the right price signals to encourage the demand side to play the invaluable role needed to achieve net zero. It is important that the consumer voice is brought into these debates, which cannot be left to technical discussions in industry dominated working groups. 

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Consultation Submissions

Success in net-zero delivery, including ensuring an inclusive transition, will require Ofgem to look well beyond the scope of this narrowly framed document. In particular: any institutional arrangements at a local level aimed at addressing net zero have to look more widely than just at energy. Even in the narrower context of energy there is a need to think more broadly about potential future challenges to the energy system.

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Consultation Submissions

We fully support the need for a Strategic Policy Statement, and also recognise that it needs to be part of the strategic objectives which have been set for Ofwat in legislation. The SPS admirably seeks to give these steers which are, welcomely, significantly more numerous and granular than in the 2017 SPS. We outline our response to Defra’s three key questions and make suggestions for improving the SPS. But we also argue that the SPS would be greatly improved if – either within the document or elsewhere – ministers set out a strategic vision for a future water industry.

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Consultation Submissions

The National Infrastructure Commission’s Baseline Assessment Report identifies the key challenges that will shape our infrastructure and quality of life for decades to come. Infrastructure has a significant impact on net zero ambitions, biodiversity, affordability and the levelling-up agenda. Identifying and addressing the associated risks and opportunities is crucial for a sustainable and resilient future.

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Consultation Submissions

While generally supportive of the substance behind the Business Plans, we call for far more consistent metrics. Affordability is a critical customer issue, but the focus on short term bill impacts should not lead Ofgem to cut back on investment to improve resilience. Two areas that need further attention are energy losses and the greenhouse gas SF6, commonly used as an effective insulator.

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Consultation Submissions

Sustainability First has been a strong advocate of innovation funding in the energy and water sectors. We hope that the following points are helpful as Ofgem learns from past experience with the Network Innovation Allowance (NIA) and the NIC and considers its future approach to the Strategic Innovation Fund (SIF).

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Consultation Submissions

To get change at the scale and pace needed to deliver on our net zero commitments, and to enable the more fundamental systems change needed to ensure the wellbeing of people and planet, competition and consumer protection laws will need to reorientate to give far greater weight to net zero and resilience. Delivering sustainability often requires a difficult balancing act, trade-offs and identification of win-wins which can be complex and challenging.

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Consultation Submissions

We support the underlying consultation proposition that net zero creates a step-change and the need for a new expert capability across electricity and gas systems. We also argue for a need to evolve whole-system approaches to energy system architecture, coordination and governance. In developing the Future System Operator role as outlined in the consultation, we also highlight areas that need more attention

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