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.
In this consultation to the Department of Energy Security and Net Zero (DESNZ) on the community benefit of electricity transmission network infrastructure we argue that greater funding and clarity on how new projects will benefit local communities is vital. We also are weary of a voluntary approach and believe communities must be properly engaged within this process
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.
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.
Ofgem is seeking views on the Annual Environmental reports that the Distribution Network Operators must produce. We want more emphasis on ensuring there is consistency in what figures are reported and want more detail on what companies are doing on potent greenhiouse gas SF6 and energy losses.
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