Consultation Submissions

The National Infrastructure Commission’s Baseline Assessment Report identifies the key challenges that will shape our infrastructure and quality of life for decades to come. Infrastructure has a significant impact on net zero ambitions, biodiversity, affordability and the levelling-up agenda. Identifying and addressing the associated risks and opportunities is crucial for a sustainable and resilient future.

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While generally supportive of the substance behind the Business Plans, we call for far more consistent metrics. Affordability is a critical customer issue, but the focus on short term bill impacts should not lead Ofgem to cut back on investment to improve resilience. Two areas that need further attention are energy losses and the greenhouse gas SF6, commonly used as an effective insulator.

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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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