Citizens Advice response to the DWG’s Target Operating Model for market-wide Half-Hourly Settlement
Citizens Advice is responding to the consultation by Ofgem and Elexon on the proposed model for electricity settlement to be used in the future.
In summary:
We can follow the DWG’s arguments for choosing TOM A “Combined Retrieval and Processing with Separate Aggregation” as their preferred TOM and we agree with them in principle. TOM A does not appear to preclude the policy decisions still to be taken by Ofgem. We welcome that the TOM will achieve a shortening of the settlement timetable, and offers opportunities for future innovations including from parties that are not suppliers.
To make a final judgement on whether this TOM is in the best interest of consumers, we would need to see a full evaluation against the TOM design principles, building on the “initial assessment” done by the DWG in 2018. We also expect to see a full cost assessment of both what the TOM’s operating costs will be in its end state, and the transition costs.
The consultation acknowledges that there are outstanding data security questions around Elexon storing all consumers’ MPAN level, half-hourly energy consumption Data, as well as privacy questions of Ofgem decides to implement an opt-out data access regime. We would like to be involved in those discussions to ensure that consumer needs around data transparency and control are respected.
Moving to combined retrieval and processing of data, and separate aggregation by Elexon may necessitate updating consumer communications . It is key that suppliers provide up to date information to customers about any changes, for example around who may collect their data from their meter and who this data may be shared with for what purposes.
We welcome the load shaping service proposal which will use a greater sample of HH data to create load shapes, making them more robust and reflective of real energy consumption patterns. However, we are keen to understand the remaining or possibly new inaccuracies the load shaping service will bring with it.
We have concerns and further questions around the time of use scaling weights suggested by Elexon.
We suggest further principles to be taken into account for the transition period from the current to the future settlement system.