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Citizens Advice response to Ofgem’s consultation on the draft Forward Work Programme 2020-22

25 February 2020

Citizens Advice response to Ofgem’s consultation on the draft Forward Work Programme 2020-22 [ 260 kb]

Citizens Advice welcomes the opportunity to comment on the areas of focus for Ofgem in its work plan for the period 2020-2022.

In particular we are pleased to see the commitment Ofgem has made to driving decarbonisation forward, made evident through its recently published decarbonisation action plan. 

There are however, some areas in which we believe Ofgem could go further:

  • The price cap has an uncertain future and we think Ofgem could do more to consider what the options are in a post price cap world and how to protect those who will be left vulnerable after the cap ends. 
  • There is also the question of resource allocation, so that in the move towards rapid decarbonisation and a changing energy market, the regulator is equipped to deal with the challenges that will arise. 
  • A crucial part of the transition to smarter, cleaner energy, is for data to be made available and more effectively used in a manner that safeguards privacy. We still believe this area needs more attention from Ofgem and a way to ensure clear benefit to consumers of sharing their data. 

We also want to take this opportunity to highlight the issue of newer technologies and services being introduced which could lead to consumer detriment. The lack of acknowledgement of this issue is a gap within the work plan.

The rapid move towards a decarbonised and smart energy system will mean that some groups of consumers may experience vulnerability in different ways. Decarbonisation will also raise questions of fairness regarding who pays for the transition. Some people are at risk of being left behind, with few choices in the market and high costs. 

We have raised these issues through research and we continue to work on highlighting these issues through our advocacy work, for example through our attendance at the Smart Systems Forum. 

We welcome Ofgem’s recognition of the need to understand the aggregate effect of its policies on groups of consumers. We encourage Ofgem to work with government and other stakeholders to anticipate these issues and develop solutions that reduce barriers to participation, protect consumers are protected, and distribute costs fairly.