Citizens Advice response to Ofgem consultation on the policy direction for the Future System Operator’s regulatory framework
We are pleased to provide a response to Ofgem’s consultation on the policy direction for the Future System Operator’s (FSO) regulatory framework. At a high level we are supportive of the policy direction that is outlined in this consultation, but nevertheless we see specific areas where the case for change could be strengthened, and others where there are opportunities to ensure that the regulatory framework maximises benefits for consumers. We summarise our main points below:
Evaluating the case for change against the actual performance of the existing regulatory framework: the development process for the FSO’s performance regulation framework must include a lessons learnt exercise of how successfully the ESO’s framework has worked in practice.
Ensuring agile performance regulation: as part of the current assessment framework, Ofgem is able to determine whether the ESO’s business plans represent value for money. However, in practice the strategic priorities of the ESO frequently change within the two year business planning cycle. As the new framework is developed, it should consider how best to assess costs in an agile way.
Achieving effective consumer representation from oversight to delivery: to ensure balanced views on a broad range of issues, effective consumer representation will be essential. As far as is possible, the engagement framework should seek to be consistent with other initiatives such as the code manager framework.
We would be happy to answer any questions you have about our response.