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Citizens Advice response to the Government and Ofgem’s Smart Systems and Flexibility Plan: Progress Update

14 January 2019

Citizens Advice response to the Government and Ofgem’s Smart Systems and Flexibility Plan: Progress Update [ 350 kb]

We welcome the opportunity to respond to the Government and Ofgem’s update. As the country seeks to meet its emissions targets, this has necessarily led to more intermittent and distributed forms of generation connecting to the grid. With these increases  there are new challenges relating to balancing the system.

While new technologies, business models and digitalisation offer real opportunities to meet these challenges, this is not guaranteed. Here a positive consumer experience will be key to ensuring success for consumers. For example, the uptake of new technologies such as smart appliances and EV’s will depend on confidence that clear consumer protections and means of redress are in place. Similarly, ensuring that individuals are able to help deliver flexibility either directly or indirectly, for example through time-of-use tariffs, depends on clear understanding of their value and assurance that consumer protections are in place. To ensure that people feel confident of their security in a new market will require that they are offered transparency and control over why their data is being collected and for what purpose.

In recent years, we have conducted research and published reports on a range of topics related to smart and flexible energy systems. Last year we also launched an ongoing research programme looking at the future of energy markets and exploring how best they can work for future consumers.  Research and reports within and outside of this programme include, “Take Charge: An analysis of the domestic electric vehicle tariff market” (2019), “Current consumer attitudes towards Smart Home technology”, “Community Energy: maximising the contribution in a changing energy market” (2018), “Consumer Expectations of Regulation: Heat Networks” (2018), “Missed opportunities and failures in the ‘time of use' tariff market” (2018), “Early consumer experiences of smart meters” (2018), “The Value of Time of Use Tariffs in Great Britain” (2017), and “The Disrupted Decade” (2016).

As with our response to the original plan, our arguments are based on fundamental principles and values, supported by evidence, that we believe should guide the UK’s transition towards a smarter, flexible energy system. Below is a summary of these principles with examples of how we have applied them to different issues covered in our consultation responses:

  • Limiting costs to consumers: for example when deciding which governance regime to put in place for aggregators;

  • Consumer protection: to limit the liability of early users of smart tariffs who find they do not work for them;

  • Transparency: to ensure consumers are clear on who uses the data generated by their smart appliances, when and why;

  • Security: of consumers’ data and privacy when using smart energy devices, which requires the development of sound, uniform standards across the industry;

  • Information: which is relevant, understandable, true, accessible, free and complete; as the energy system becomes more complex, as smart tariffs, meters and other appliances fill the market, information will be key;

  • Fairness: for example when deciding who should pay for the development of smart charging infrastructure for electric vehicles;

  • Cost-reflectivity: for example in distributed generation support;

  • Vulnerability: to ensure vulnerable consumers are not adversely affected by products or services which might not be suitable to them, but equally that they do not suffer indirectly because they are not able to access them.