Citizens Advice response to the ENA Flexibility Consultation 2022

Citizens Advice response to the ENA Flexibility Consultation 2022 [ 120 kb]

We welcome the opportunity to respond to this consultation and give our key points below.

Development of flexibility markets is of vital importance to net zero
We value this continued engagement with stakeholders on flexibility services as consultation is a vital part of developing the appropriate tools, processes, products, and supporting contractual framework to facilitate increased use of flexibility in the energy system. Flexibility resource usage, including demand side response (DSR), must be maximised to achieve a rapid net zero transition at the lowest possible cost to consumers.

Focus on lower voltage flexibility markets
The Open Networks project will need to accelerate the development of standardised processes and products across pre-qualification, procurement, and dispatch to build engagement and confidence in flexibility markets. These are necessary steps to ensure that the widest number and range of participants will provide flexibility resources. In particular, we believe that the Open Networks project needs to have a much higher focus upon encouraging lower voltage participation, including from aggregators which are engaging with domestic and small businesses. The Distribution Network Operators (DNOs) need to develop lower voltage flexibility markets to a much greater extent than at present. Reporting of flexibility tenders and contracted volumes should be given at different and for lower voltage levels for transparency of progress.

Consistency to drive efficiencies
Any reporting methodologies need to be consistent across the wider energy sector and beyond (e.g. water sector) and not just across the DNOs, or between the DNOs and the ESO. There should also be a priority to ensure that methodologies and reporting are as consistent as possible with any requirements under the Ofgem RIIO-ED2 price control to maximise efficiency in delivery.