Citizens Advice response to ENA Open Networks Project 2021 Project Initiation Document consultation
We welcome the continued focus on openness and transparency of the Open Networks project through its consultation processes, its meetings and webinars, and in its publications surrounding individual workstreams.
The ENA Open Networks project will need to ensure that its workstreams move at pace to accommodate and progress developments in the transition, including ensuring that the project links with BEIS and Ofgem developments. For instance, the ongoing Ofgem electricity distribution price control process (RIIO-ED2) is of high relevance.
Distribution System Operation (DSO) Roles and principles and energy efficiency
The Open Networks project will need to be reviewed to ensure that the new DSO Roles and principles outlined by Ofgem in the ED2 Business Plan Guidance are taken into account within the workstreams. We would recommend that an energy efficiency workstream is developed in response to these new DSO requirements.
Flexibility services
We welcome the work to lay down principles for the review of legacy Active Network Management (ANM) curtailment contracts which have been identified as potentially impeding future flexibility markets. We note the consultation on the subject which is scheduled for September 2021 and we look forward to contributing to that consultation and also seeing the views of other stakeholders. We recommend that cost recovery methodologies for any renegotiation of legacy Active Network Management contracts should be transparent and open to stakeholder input.
Consumers in vulnerable circumstances
We note the DSO workstream has an ongoing sub-workstream for ‘Potential Conflicts of Interest and Unintended Consequences’. While the information on this topic is available for review or further input by the other workstreams and wider stakeholders, we are concerned that this vital part of the Open Networks project could be overlooked as there is no plan for any active development in this area during the coming year. We recommend that this workstream is actively reviewed in 2021 and that the ENA Safeguarding Group is invited to contribute (among other stakeholders) given this forum’s wide energy network industry knowledge of consumers at greater risk of harm, detriment or disadvantage. We recommend that the workstream be widened to consider how the Open Networks project workstreams can be used to positively address the needs of those in vulnerable circumstances including ensuring that all groups benefit in the transition to net zero.