Citizens Advice response to Ofgem Consultation on Energy code reform phase 1: transitional measures and code changes
We welcome this opportunity to contribute to the ongoing development of energy industry code reform. We support code reform as it should lead to:
Consistent processes and more speedy decision-making across all codes
Independent chairing for all codes, as well as experienced industry input and scrutiny to changes in code requirements
Easier access for parties to raise codes, especially smaller parties or consumer groups
Increased transparency in processes, decision-making, and appeals.
We support many of the proposals in the consultation. However, in discussions with industry, it appears that there is still a level of uncertainty surrounding the details of performance measurement for the code managers. If there is sufficient time before the first code manager 'go-lives' for the Balancing and Settlement Code (BSC) and Retail Energy Code (REC), we recommend that there should be another industry workshop to discuss and further refine the performance methodology.
If there is insufficient time before 'go-live' to enable further discussions with industry on code manager performance measurement, we recommend that there is a review, perhaps one year after implementation, to assess the performance management framework to understand its effectiveness and to make refinements, if necessary.
We welcome the requirement (as detailed in Figure 4, page 28 of the consultation) for the code manager to provide a narrative detailing how they have furthered "the relevant objectives (including innovation, customer outcomes and net zero)". We would welcome further information about how this narrative would be provided and whether any formal performance metrics or measurements could be used in this area. Performance assessment could be directly related to the code objectives and/or the requirements of the Strategic Direction Statement (SDS). Measurable elements could include, for instance, enablement of faster connections or rollout of hydrogen infrastructure. Narrative explanations, coupled with numerical information, could describe, as an example, how the code manager has improved protection for all consumers, particularly those in vulnerable circumstances (e.g. savings to all consumers, or to those in vulnerable circumstances).
We would welcome clarity on how the 'code manager business' of the BSC that is not directly related to routine code manager functions is to be performance-measured. These additional activities are listed on page 17 of the consultation and are:
Operation of, or procuring the operation of, the central system comprising the BSC Systems (as defined in section X-1 of the BSC)
Smart Secure Electricity Systems (SSES) Governance