Consultation Submissions

We welcome Ofgem’s consultation on approaches to local energy institutions and governance but would like Ofgem to think more deeply about the practical reality that local actors face in delivering net-zero. This includes Ofgem taking a far broader view of what ‘good outcomes’ look like in an energy world where place matters. We also want more discussion on how the Future System Operator is best-suited to the role of regional energy-system planner and market facilitator. 

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We agree with Ofgem that prepayment is a preferred payment method for many consumers given the budgeting control it offers. We are not in favour of a ban on prepayment provided suppliers are behaving responsibly, provide good service, are treating customers fairly and complying with their licence obligations.

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One of the factors that is important in Ofgem's calculation of the price cap for Economy 7 customers is the assumption on the split between day and night usage. We are concerned that updating this one aspect in isolation could have adverse consequences. We would therefore like to see wider review of Economy 7 customers in the price cap.

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We are pleased to see specific reference to Economy 7 customers in your latest Call for Input, but are concerned that Ofgem is only proposing to look at the narrow question of “additional wholesale allowances”. As set out in the It's a Lottery report, by Gridge Edge Policy, the concern for Economy 7 customers relates to total wholesale costs

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We are very struck that nowhere in the consultation is there any discussion of the impacts of the proposed changes on Profile Class 2 (multi-rate) customers, who pay different amounts depending on when they use energy. It appears that changes could have a bigger impact on these customers than it does on customers on a standard rate tariff.

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In our submission to Ofgem on Future Systems and Network regulation, we highlight four areas that we think the regulator needs to address. Firstly, the need for investment given the significant challenges around net zero and the demands of national energy security; secondly managing uncertainty around the role of hydrogen and heat decarbonisation; thirdly the importance of adaptive planning and lastly strengthening the networks’ role on social and environmental issues

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