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Citizens Advice response to ESO consultation on Enabling the DSO transition

20 May 2021

Citizens Advice response to ESO consultation on Enabling the DSO transition [ 240 kb]

We are pleased to see this consultation and the development of an approach for the ESO to support and enable the DSO transition. However, we recognise that the roles and responsibilities for ESO and DSO functions are still evolving and that there continues to be a lack of clarity as to the exact functions each party will undertake. It is critical that there is a successful DSO transition with an excellent interface with the ESO for net zero to succeed and for the energy system to meet consumer needs at the lowest cost. We would encourage the ESO to take an approach that is adaptable to the ongoing development of the DSO transition and not to have a 2025 vision which is fixed and based on early stage DSO development. 

Whole system approaches will be key to unlock best value for consumers in the transition. We have outlined with our response some detailed aspects regarding our views on whole systems. In summary, we believe that the ESO should play a role in ensuring whole systems thinking is achieved for the ESO, transmission, and distribution systems, via its coordinating functions in code governance and operations, charging regimes, forecasting, network development, efficient connections, and in market operations including tendering, contracting, and dispatch.  

Further recommendations within our response:

  • The principles and vision should include a focus upon stakeholder engagement and explain the mechanisms that will be used to ensure stakeholder views are fully taken into account.

  • The ESO should use an iterative and transparent scheduled process to ensure incorporation of new requirements or developments. 

  • The ESO should consider its own role with the DSOs regarding energy efficiency and in DSO/DSO boundary management which may necessitate a revised 2025 vision.

  • Aspects relating to conflict management, unintended consequences, and consideration of those in vulnerable circumstances have a continued and higher focus within the Open Networks project and also that they should be reflected within the 2025 vision.

  • We welcome rationalisation and simplification of the Grid and Distribution codes.

  • An overarching whole systems aim should be part of the 2025 vision.