Citizens Advice response to SPEN Fusion USEF Consultation
Citizens Advice welcomes the opportunity to respond to this consultation as part of its statutory role to represent domestic and small business energy consumers in Great Britain (GB).
The Fusion project represents an interesting contribution to the development of the flexibility market and its operations in GB. The practical trials planned for East Fife should provide information to assist in the evolution of this nascent market at the electricity distribution network level.
The underpinnings of the Fusion project are proposed to be the Universal Smart Energy Framework, which has been drafted by seven industry participants, and gives recommendations to facilitate an effective flexibility market. In our meetings with SPEN it has become clear that one of the aims of this project is to test the suitability of USEF for application in GB markets.
The USEF has been designed on a ‘roles’ basis, identifying and allocating roles for each element of the flexibility market. We note that this framework differs in approach from the flexibility market development work of the Energy Networks Association Open Networks project (ENA Open Networks) where the various functions are considered in terms of the actors that could facilitate the market. In addition, we are aware that the ENA Open Networks project, which is tasked by industry, BEIS and Ofgem, to facilitate the development of the flexibility market, are also engaging with similar consultations and developments within this field.
We note that many of the questions within the Fusion USEF Consultation Document address a number of the same issues being consulted upon or developed by the ENA Open Networks project (e.g. within their July 2019 Flexibility Consultation). We understand that there is communication with ENA and Ofgem on these issues, but we want to stress that it is vital for consumers that there is consideration of wider policy issues regarding the emerging flexibility market. We believe that these policy considerations must be aligned with the ENA Open Networks project’s policy work to ensure that there is not an inadvertent divergence in the progress of the GB flexibility market which may hinder its rapid establishment. As such, we recommend that future Fusion consultations regarding policy issues are very closely coordinated with ENA to ensure that a single, efficient and coherent policy development framework is established for the GB market.