Citizens Advice Response to ESO Early Competition Plan Phase 3 Consultation
Citizens Advice is contributing to the ESO Networks Stakeholder Group (ENSG) work on early competition and support the work of the ESO in developing a proposed model. We believe this work presents an opportunity to increase innovation across planning, design, construction, finance, operation and maintenance of assets in network projects. This would support service benefits and cost savings to consumers.
Positive outcomes from early competition require alternative delivery options from third-parties that offer advantages over proposals from monopoly networks. However, we are conscious that there are natural resource synergies of network planning being vertically integrated with network delivery and operation in a Transmission Operator (TO). TOs are funded to plan and deliver their networks and it is in consumers’ interests this resource is best utilised.
As noted by the ESO, these responsibilities are split from network delivery into different organisations in some countries. These roles are within the TO in Great Britain - and we see strong advantages of this approach - but it will make it difficult to create a neutral platform for competition against a monopoly network planner and operations provider. This has been raised by stakeholders in earlier consultation phases of the ESO’s work. The incumbent and other TOs have significant advantages that need to be monitored and addressed, including connection process, energy cost, cost of capital, user charges and land and development rights.