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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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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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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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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