Citizens Advice response to consultation on DNOs' future role in supporting the rollout of low carbon technologies
Citizens Advice wants Ofgem to ensure that any DNO involvement in energy efficiency and low carbon technologies, whether operationally or in terms of financing, does not distract the DNOs from their core activities.
While we want to ensure that all households are able to participate in any energy transition, it is not the statutory role of DNOs to address this problem. We would need to see more evidence of correlation between network needs and fuel poverty to support fundamental changes in the role of DNOs. We consider that local authorities are a more natural home for targeting support at those in fuel poverty and we are aware that many DNOs (and GDNs) already work closely with local authorities. Indeed, we expect to see further coordination through NESO’s Regional Energy Strategic Planning (RESP) programme.
If Ofgem wishes and is legally able to pursue changes to the role of DNOs through ED3, we can see a stronger case for DNOs playing a larger role in the way that energy efficiency and low carbon technologies are co-ordinated. We can see opportunities for efficiencies which could, ultimately, lower the costs and inconvenience for energy consumers. While we can see the rationale for a coordination role for DNOs, we are unconvinced by the evidence provided so far.
We are unconvinced, based on the evidence provided by Ofgem, that DNOs should take on an expanded role for LCTs and energy efficiency during ED3. We therefore recommend that Ofgem does not pursue this further unless compelling evidence emerges before SSMD. We are open to Ofgem exploring the role of DNOs and building the evidence base ahead of the 2033 - 2038 ED4 price control.