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Ofgem’s open letter on embedded benefits

30 September 2016

Embedded Generation response [ 230 kb]

This is Citizens Advice’s response to Ofgem’s open letter on embedded generation. Our principal recommendations are:

  • Sub-100MW embedded generation’s avoidance of the demand residual charge needs to be addressed

  • A Significant Code Review should be initiated to take a wider, holistic look at TNUoS charging.

We support Ofgem’s proactive approach in initiating this open letter, rather than leaving it to deliberating upon CUSC modifications alone. We believe it is likely that the current arrangements are causing significant consumer detriment. It is an important part of Ofgem’s duty to consumers to make sure that issues surrounding embedded generation are addressed.