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Citizens Advice response to ENA consultation on the Open Networks Project Phase 4 2020 Project Initiation Document

17 March 2020

Citizens Advice response to ENA consultation on the Open Networks Project Phase 4 2020 Project Initiation Document [ 140 kb]

The Energy Networks Association (ENA) Open Networks project is an important part of the low carbon energy transition of Great Britain in helping to drive and coordinate the changes that are required by the gas and electricity network companies. Citizens Advice supports the work of the Open Networks project via our membership of the ENA Open Networks Project Advisory Group and in responding to the Open Networks project’s consultations. In our consultation response, we note our recent publications outlining our views of priorities concerning the development of flexibility markets and other net zero transition activities.

We support many of the priorities of the ENA Open Networks project, including the need for rapid development, the least regrets policy, and the need for transparency and openness. We also noted the following priorities:

  • The need to identify barriers to transition for those in vulnerable circumstances and how the project could mitigate or overcome those barriers
  • Addressing retail market arrangement issues relating to flexibility and transition issues
  • Rapid visibility of distributed generation and low carbon technologies that are attached to the network to assist in the development of a more efficient and low carbon energy system
  • The transparency of other network data, subject to appropriate consumer protection, so as to facilitate the development of flexibility markets and to foster innovation
  • Ensuring that consideration of fairness and transparency in dispatch decisions for flexibility have a high focus alongside tendering decision-making procedures
  • Continued engagement with stakeholders, consumers and network customers to confirm the correct direction of travel, identify challenges and solutions, and to support the implementation of actions
  • The establishment of clear boundaries between Distribution Network Operator (DNO) activities and DSO functions to understand appropriate costing of these functions, and to facilitate any future requirement to transfer DSO functions to non-DNO parties
  • The elimination or mitigation of apparent or actual conflicts of interest
  • Ensuring that energy efficiency is incorporated as an option within Cost/Benefit analysis as an alternative to infrastructure investment decisions
  • Working with regulators, industry companies, and bodies responsible for code development to remove barriers that could impede successful change