Citizens Advice response to ENA Open Networks Flexibility consultation

Citizens Advice response to ENA Open Networks Flexibility consultation [ 210 kb]

We have previously contributed to the Open Networks project through responding to the Commercial Principles consultation, the September 2018 Open Networks: Future Worlds consultation, and the February 2019 Open Networks Future Worlds consultation. We also sit as a member on the Open Networks Advisory Group. 

We support the work of the ENA Open Networks project and highlight the need for rapid development of the flexibility market as representing a vital element to enable the United Kingdom to meet its 2050 carbon reduction targets. Lower costs for consumers should also be an outcome of a deep and active flexibility service market. The joint Ofgem/BEIS Open Letter to the ENA Open Networks project in July 2019 recommended the progression of least regrets actions. We uphold the same view while also recommending that there is continued and further engagement by network companies with stakeholders, consumers and network customers to confirm the correct direction of travel and to support the implementation of actions.    

We note the increased focus on standardisation and simplicity within this workstream and support the drive to common contractual terms and conditions. We would welcome a speedier outcome to this particular aspect of the Open Networks project as standardisation of branding and naming of services, and the use of common legal terms and contractual arrangements should facilitate participants entering the market and being able to easily contract with multiple DSOs and the ESO.