Response to ENA’s Statutory Voltage Limits Consultation

Response to ENA’s Statutory Voltage Limits Consultation 327 KB

Citizens Advice welcomes the opportunity to respond to the ENA’s consultation on the proposal of modernising the Statutory Voltage Limits. We recognise the potential system-wide benefits of lowering the statutory voltage limit. However, while the consultation sets out potential benefits and challenges, we do not consider the evidence base sufficiently comprehensive to support an immediate decision.

Before we can determine whether to support the proposal, several key issues need to be addressed.

• The consultation does not assess alternative approaches to support the increased connection of low-carbon technologies (LCTs) while reducing barriers to their connection. Given the potential impacts on consumers, a comprehensive analysis of options - including their cost, risks and benefits - is necessary to determine whether the change of statutory voltage limit is the most appropriate and proportionate solution.

• There is insufficient transparency on how the potential costs of the statutory voltage change will be distributed and recovered. Greater clarity is needed. And there is no clear analysis of the financial impact on small businesses. Without a comprehensive assessment, it is difficult to evaluate the proposal's fairness. 

• Further evidence is required on the consumer impacts. This consultation and the technical report acknowledge the potential effects on  appliance performance, but the testing is limited and does not include storage heating systems and medical equipment used in homes. The impacts on vulnerable households, including medically dependent consumers, had not been fully assessed. Stronger evidence and clear safeguards are needed to mitigate risks.

• A clear and proactive communication strategy is needed before any changes are introduced. Consumers should be informed about what is changing, what impacts may occur in practice, and where to seek support if problems arise. Effective communication will be essential to maintaining consumer confidence. 

• A phased implementation requires further development. A clear “go / no-go” criteria for progressing beyond the first phase, along with defined support and redress mechanisms, and transparent monitoring arrangements must be established before the implementation proceeds. 

• We would welcome more information from the ENA and its members about voltage levels at the LV level, recognising that DNOs should have comprehensive monitoring in place.

Overall, while the proposal may deliver long-term benefits, effective communication, stronger evidence, clearer governance, greater transparency on cost distribution and LV performance data, and robust protections for vulnerable consumers are needed before changes to the statutory voltage limit can be satisfactorily justified.