Citizens Advice response to Electralink consultation on Flexr: the energy data sharing service
There is a clear identified need by public bodies and other organisations for energy data repositories with open, transparent and objective access requirements. It is in this light that the Electralink Flexr product has been proposed which aims to provide a Distribution Network Operator (DNO) data provision and standardisation service to facilitate the energy market transition.
We are pleased to respond to this consultation regarding the proposed Flexr service and raise the following points. Please see the full response for more details.
There may be potential consumer detriments if the Flexr service does not achieve the expected outcomes or through possible competition issues. As such, we recommend that the Flexr project coordinates with the Energy Networks Association Open Networks project and that Ofgem provides clear principles for such services as well as monitoring potential competition issues.
We recommend further inclusive engagement with stakeholder groups, including smaller groups such as community energy groups or housing associations, to ensure that the service is designed to meet all needs.
We support the use of pre-existing models for the governance arrangements for the proposed Flexr service. It may be preferable to use the Distribution Connection and Use of System Agreement (DCUSA) model with the additional schedule which may offer the ability to more readily facilitate transfer of the Flexr service to another provider in the future, if deemed appropriate.
It would be valuable to undertake further consultation regarding the possible cost recovery methods beyond 2020 including considering other options such as a hybrid system with part socialised costs and part user costs, for instance. Further consultation should also include details of the likely costs of development, ongoing costs and timescales, as well as modeling of possible fee levels and structures. It would also be valuable to understand the business model regarding whether the Flexr service is intended to be profit-making or a purely cost-recovery service.
On data privacy and security, it would be useful to understand how accessible and transparent the user options are and how suitable they would be for a wider group of people and organisations.
We welcome Electralink’s strict governance arrangement when sharing non-anonymised data with those outside the Data Transfer Service agreement. We would be interested in hearing more about this process.