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Citizens Advice response to ENA Flexibility Consultation 2021

5 October 2021

Citizens Advice response to ENA Flexibility Consultation 2021 [ 150 kb]

We are pleased to respond to this consultation given the importance of flexibility in contributing to meeting the needs of net zero goals. 

We have the following recommendations and comments:

  • That there should be an equal focus on the use of energy efficiency to meet network Distribution System Operation (DSO) needs when compared to flexibility. There are potential advantages in using energy efficiency to alleviate the need to reinforce network infrastructure and to meet other net zero aims. The targeted use of energy efficiency can also support those that are on low incomes or have other vulnerabilities. Consideration of the use of energy efficiency is a requirement on Distribution Network Operators in their DSO requirements and as a licence condition.

  • It would be helpful to have a narrative explanation in addition to the Flex figures provided on the ENA website. This narrative could explain the progress of the use of flexibility services as well as the differences between the development of the use of these services between the companies.

  • On a principle basis, it would appear better to have aligned DSO and Electricity System Operator market procurement to progress efficient tendering and procurement of flexibility services. We note that other stakeholders, such as flexibility providers, will have user experience on this topic and therefore be able to contribute more effectively on the topic and also describe the nature of any disadvantages to delay alignment. 

  • We have noted in previous consultation responses the need for the issue of flexible connections under Active Network Management (ANM) contracts to be given due consideration as these contracts could be in perpetuity and had been entered into with a potential imbalance of knowledge between the DNO and the customer. We note the project has identified that there is a process for exiting such contracts and that there will be an emphasis on improving the visibility and communications of this process. We welcome the drive for customers to understand that they can exit these contracts. Customers should be informed of any cost implications, including the potential effects from changes to charging regimes from the Access and Forward Looking Charges Significant Code Review (Access SCR). It was not clear from the consultation that this aspect had been considered or the implications of a different charging regime may possibly mean that customers may be better waiting to exit contracts. We would welcome further information about the costs of exiting such contracts and the implications for customers from the Access SCR. We would expect that cost implications would be fully explained to customers wishing to exit a flexible connection contract, including any lower-cost options that might result from Access SCR changes. 

  • We would also welcome from the Open Networks project an analysis of implications of the Access SCR changes and the potential extent of cancellations of flexible connections contracts, including the needs and costs of networks to respond through either increasing flexibility services procurement, or other measures, such as increased use of energy efficiency or traditional reinforcement. 

  • We welcome a focus on targeting all potential flexibility provision, including the potentially sizeable and growing use of flexibility from residential properties. The use of such flexible resources will be necessary to meet net zero ambitions as well as to ensure that network costs that consumers have to pay are as low as possible.