Citizens Advice Response to BEIS Consultation on the Smart Export Guarantee
Citizens Advice welcomes the government’s proposal for a Smart Export Guarantee.
In our response to two previous consultations, we expressed concerns that the abrupt closure of the export tariff alongside the generation tariff could leave small-scale generators without a clear route of access to market. The proposed Smart Export Guarantee should help to bridge this looming gap and should help the nascent market for small-scale generation to find its feet. However we still recommend several important changes to the government’s SEG proposal.
We continue to recommend that the backstop price in the obligation be linked to the market price of electricity, discounted to reflect reasonable administrative costs. We believe that a backstop price designed in this way will be sufficiently high to attract continued investment in small-scale generation, but sufficiently low that it will not undermine the development of a private market.
We also repeat our previous recommendation that the government publish a roadmap laying out how and when outstanding export data issues will be resolved, with a clear accountability framework for its delivery. If export data issues are expected to persist beyond the time the SEG legislation is due to enter into force, we propose that the government should mandate that suppliers offer a deemed, flat-rate, export tariff on a provisional basis to any small-scale generators facing export data barriers through no fault of their own. These generators would then be moved on to a metered export tariff once these export data issues are resolved.