Citizens Advice response to consultation on the RIIO-2 Re-opener Guidance and Application Requirements Document
This submission responds to the second Ofgem RIIO-2 draft re-opener guidance document consultation which incorporates revisions from the prior consultation from October 2020.
The RIIO-2 re-opener process will be part of the required re-opener licence condition for the energy network companies. Adherence to the guidance should enable a timely and informed decision on any re-opener application and any failure to follow the guidance may result in rejection of the application.
We have the following recommendations that:
Ofgem considers whether redactions that are made are actually necessary when considering the application.
It would be useful to have a standard format, at least for core or common re-opener elements, which would assist Ofgem and other stakeholders to more rapidly assess re-openers.
Ofgem needs to consider the risk that with a demanding workload they may be stretched to ensure that decisions are made in a timely manner and with full scrutiny given the potential volume of re-opener applications. We would also ask that the 9 month process timeline is reviewed after the first year of re-openers to assess whether this timeline is still appropriate for network companies and stakeholders to be able to respond to net zero targets or other requirements.
We are pleased to see that there is now a requirement for stakeholder engagement for every re-opener application.