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Citizens Advice response to ENA Flexibility Consultation 2020

8 October 2020

Citizens Advice response to ENA Flexibility Consultation 2020 [ 200 kb]

This submission responds to the ENA Flexibility Consultation 2020. We welcome the continued engagement with stakeholders for the Flexibility and associated workstreams. We believe that consultation and the use of workgroups are essential to capture views and ensure that there is ongoing progress in this vital contribution to the achievement of net zero.

Our key recommendations are that:

  • The Flexibility workstream, associated workstreams, and the Open Networks Product Initiation Document are reviewed in light of the proposed DSO Roles and Principles within the RIIO-ED2 Methodology Consultation to ensure that the workstreams and whole Open Networks project are aligned to the proposed DSO requirements.

  • The members of the Common User Methodology User Group are drawn widely enough to ensure full coverage of relevant industry and current and future market participants. These should include smaller industry participants, consumer groups, and representatives of community energy groups, for instance. 

  • The Flexibility workstream incorporates the promotion of energy efficiency within its Cost Benefit Analysis work, including how this potential option can be incorporated into the methodology and tools being developed. 

  • Firm new target dates are given for the following steps for the baselining methodology, such as for any further consultation, and for implementation of any best practice standards.

  • Stakeholder and regulatory input is sought as to whether previously-contracted and new flexible connection arrangements are a barrier to effective secondary flexibility service markets, and to look at a range of potential solutions.

  • A timeline is assigned to all of the next steps for the DNO Flexibility Services Revenue Stacking programme following prioritisation resulting from this consultation.  

  • A review of the types of technical barriers that may impede smaller participants or domestic users from tendering as a flexibility provider. 

  • ENA discusses with DNOs whether their stakeholder engagement groups and online panels may be a useful means to obtain further feedback for ENA Open Networks consultations as these groups are already established and usually have wide membership. ENA engagement with community energy groups would be valuable as well as the use of interactive online and social media platforms to ensure the widest reach.