Ofgem consultation on the change process for the generation capacity mechanism
Consulation response extract
Following is our feedback on the process for modifying the Capacity Market Rules (‘CM Rules’). This submission is non-confidential and may be published on your website.
We are uncomfortable with the proposals contained in the consultation and believe that they will not result in a robust process. In particular, we think that:
- the timescale is unrealistically truncated for assessing what could be highly material changes;
- a process will be needed for prioritising workload rather than trying to assess – and consult on - all proposals to the same timetable;
- the proposed development process looks opaque, and may hamper stakeholders’ ability to develop an understanding of proposals or to provide input at a time in the process when they are still in development.