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Citizens Advice response to ENA’s Open Networks commercial principles paper

2 October 2017

In this consultation response [ 270 kb], we comment on the Energy Network Association’s proposals for how Distributed Energy Resources (DER) can be best used by the electricity system in the future. DER - that includes solar panels on people’s roofs, a wind farm run by a community group, an Electric Vehicle outside your house, and a supermarket’s fridge and freezer units. This energy can be used to manage the electricity system more efficiently - the question is how this will be done and by whom.

In this response, we state that:

  • Any future model for procurement and operation of DER should be as efficient as it can be to deliver savings or avoid additional costs to consumers.  

  • When designing procurement and operational processes, the National Electricity Transmission System Operator (NETSO) and Distribution System Operators should ensure that they are accessible to a wide range of DER owners. Part of the solution is that DER owners can participate in markets via an aggregator of their choice.

  • Suppliers and aggregators could play an important intermediary role between DER owners and DSOs and the NETSO. This should be further explored in the customer experience workstream of the Open Networks project.

  • We would like to see congestion management at distribution level move towards a state whereby forced curtailment only takes place in emergencies. DER owners should be able to choose between a firm and flexible connection, and separately choose whether they want to offer their flexibility in exchange for payment.

  • The paper leaves it open to what extent participation in flexibility markets will be voluntary or may be compulsory under certain circumstances (e.g. will the NETSO or a DSO have powers over DER without the owner’s consent in emergencies?). We would welcome further discussion on this in coming Open Networks meetings.