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Response to Ofgem/BEIS call for evidence on a smart, flexible energy system

16 January 2017

A response to BEIS' and Ofgem call for evidence [ 450 kb]

Response to the call for evidence from the Department for Business, Energy and Industrial Strategy (BEIS) and Ofgem on “a smart, flexible energy system”.

We greatly welcome this joint call for evidence as it puts a timely focus on the fast-changing UK energy system.

In our 25 responses to BEIS’ and Ofgem’s questions we have drawn on our experience as an energy champion and advice charity. We have conducted research and published reports on multiple topics related to smart and flexible energy systems. Throughout our responses, 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.

Whilst this consultation covers many topics which are relevant to addressing the challenges on our way to a ‘smart’ energy system, we are concerned that its structure may end up missing both the bigger opportunities and the bigger problems in that transition. There is a risk that by narrowly dividing questions into different technologies, actors and policies, the overlaps and conflicts between them may be missed.