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Citizens Advice response to ENA Open Networks High Level Scope Consultation 2022

15 November 2021

Citizens Advice response to ENA Open Networks High Level Scope Consultation 2022 [ 150 kb]

We welcome the opportunity to comment on the ENA Open Networks project 2022 high level scope consultation. We note that the consultation was issued prior to the issuance on 19 October 2021 of the government’s many net zero policy and strategy documents. It may be necessary to revise the scope in light of these documents, in particular, the Net Zero Strategy, with its increased emphasis on development of onshore and offshore wind power and its interaction with the electricity networks. We are aware that there will be a forthcoming joint BEIS and Ofgem Electricity Networks Strategy that may affect the priorities of the Open Networks project. Ofgem may be consulting upon Distribution System Operation (DSO) governance in 2022, which also may necessitate redevelopment of the Open Network project’s 2022 plan. It may be necessary, therefore, for the project to be responsive to these policy and strategy developments and refine plans on an ongoing basis. The project’s Steering Group and proposed new Challenge Group may be useful to guide any continuing changes in direction for the project, with appropriate stakeholder input to ensure that the direction is the right one.

User forums
We note the intention to use specific user forums for separate programmes within each workstream. This will need stakeholders to join potentially very many different user forums, with an increase in time demand, compared to the prior Advisory Group format where many work programmes were presented to the whole Group. It is possible that uptake for these user forums will be limited with a risk that the attendees will represent a narrow stakeholder viewpoint. The alternate options of using the other groups that will follow the closure of the Advisory Group, namely the Challenge Group, Dissemination Forums, Focus Groups, and focused workshops, may offer a good solution for generating stakeholder engagement.

We recommend that the membership and numbers of any user forums are monitored, and after a period of time, perhaps 3 to 6 months, the engagement with and by these forums, and the use of the alternate groups, are assessed. If the membership appears to be less representative than in the former Advisory Group, and the input to the process is diminished, reconsideration should be given to reestablishing a wider stakeholder group that can consider the progress of many workstreams in one session.

Specific workstreams
We welcome the continued focus upon flexibility, the increased focus on whole systems, and the commitment to have a stakeholder engagement review in 2022 to ensure all relevant stakeholders are identified. We would also recommend that a separate workstream be developed to consider the role of energy efficiency within Distribution System Operations, or, as an alternative, to have the flexibility workstream expanded to also cover energy efficiency.