Citizens Advice response to ENA Open Networks consultation on the Common Evaluation Methodology tool
We welcome the opportunity to respond to this consultation as the Common Evaluation Methodology (CEM) is a useful tool in the assessment of options for choosing between traditional reinforcement and alternatives.
We have the following comments:
Clarity, transparency, and ease of use - The selection of a branching or tree structure, with probabilities assigned to the likely scenarios, appears to be a sound basis for the CEM, although there may be alternative options models that might achieve better outcomes. Other stakeholders, with financial modelling experience as noted within the webinar, may be able to suggest other alternatives. However, the need for people to feel confident in its operation could mean that a simpler, but still largely robust model, would be preferable for use.
Choice of scenarios - We prefer the use of the National Grid Future Energy Scenarios (FES) to develop the probabilities to be used in the model given its independent origin and the narrower range of scenarios compared to using Distributions FES.
Energy efficiency - The CEM tool does not appear to adequately incorporate energy efficiency as an alternative to reinforcement or flexibility. We would recommend that further work is undertaken to incorporate energy efficiency options, and that consideration is given to developing a joint Whole System CBA and CEM tool to capture more alternatives.