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
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.
In our latest consultation, we are disappointed that Economy 7 customers did not feature in Ofgem's programme of work for the price cap which it is currently consulting on. We strongly believe it should, as such customers account for 10% of all households
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
Generally we are supportive of the Data Best Practice Guidance as a response to the Energy Digitalisation Taskforce recommendations and the evident challenges of meeting net zero. We support the idea that de-personalised, (suitably aggregated or anonymised), smart meter data held by Distribution Network Operators should be treated as Energy System Data and subject to the requirements of the Data Best Practice guidance.
We outline our response to the proposed Review of the Electricity Markets Arrangements (REMA) in a letter, and answer a series of questions. We argue that it is vital that the impact on end-users of these reforms is considered, because the changes will have far-reaching implications for decades to come.
Download letter
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We outline below our high-level response to water regulator Ofwat’s key PR24 draft methodology and the answers to a selection of the questions posed.
Whilst there is much to support in the Draft Determinations, for example on low carbon technologies, efficiency, and consumer engagement, Sustainability First has a number of concerns that we raise in our response to this consultation, including the failure to adequately incentivise environmental performance, insufficient focus on tackling distribution losses, inaction on the potent greenhouse gas SF6, and the decision to reject company proposals for energy efficiency measures that would help customers in vulnerable situations.
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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