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
There are areas we welcome, such as making policies inclusive by design and encouraging innovation in vulnerability strategies, but we’d welcome a more explicit focus on prevention of harm so that individual customers are protected via well-designed services.
Heat networks are expected to play a crucial part in the decarbonisation of heating. This requires heat networks to be accepted by consumers, raising greater awareness, consistent high standards of provision and reasonable pricing. We also need additional protection for those that need it. Read why we think the proposed approach will fall short and cannot deliver alone.
We welcome Ofgem's proposal to allow additional funding to National Gas Transmission to cut methane leakage from its network; this is an important way to tackle climate change as reflected in the Methane Pledge that the UK government signed at COP26. We urge Ofgem to build on this and set more ambitious methane reduction targets as it considers the next price control, RIIO-3.
In responding to Ofgem's call for input on domestic energy flexibility, we argue that it lacks a clear focus on how domestic flexibility might evolve in practice and gain momentum. Importantly it lacks insight into how to achieve greater consumer engagement for a flexible energy system.
Enabled by the Energy Act 2013, we are hopeful that the Strategy and Policy Statement will be introduced in 2023 to provide broad strategic direction and a clear indication of government priorities, both to the energy regulator and the Future Systems Operator. Seeing government priorities transparently in this way is vital for stakeholders and creates a more robust legal framework.
In response to the Department for Energy Security and Net Zero's consultation on an innovative retail market, we encourage Government to ensure that consumers are appropriately protected in a more innovative retail market, drawing lessons from our past work including on the Economy 7 energy tariff
It is vital that regulators drive the right kind of growth with their rules. In our latest consultation, we are not in favour of extending the 2015 Deregulation Act Growth Duty to Ofwat and Ofgem. There is a risk, that despite its intentions, the Duty has unintended negative consequences by strengthening industry interests at the expense of consumers, wider society and the environment.
Ofgem is exploring alternative models for how it regulates the network companies. We agree that the pace and scale of investment needed in electricity networks means new approaches may be needed. However we are concerned that this sort of radical review risks creating a hiatus when we do not have the time.
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