Citizens Advice response to the Ofgem proposal to review competition in the electricity connections market for RIIO-ED2
We support the proposal to review the level of competition in the electricity connections market in advance of the RIIO-ED2 price control period. This review should help to ensure that consumers are receiving the best value and access to a wide selection of competitive services in the electricity distribution sector.
We note the potential value in ascertaining whether separating some functions from DNOs to a separate DSO body or bodies may provide better assurance for third parties in competition considerations. For instance, an independent DSO could assess whether an Independent Connections Provider can determine the point of a connection, and provide independent assurance that all competition opportunities have been identified and progressed. We recommend that the merits of an independent DSO and its role in distribution level competition should be reviewed to identify whether this is the most appropriate way forward to enable greater and more efficient competition in connections.
The Competition in Connections Code of Practice (CiCCOP) (latest version - v1.5 October 2019) notes that the competition process begins when an application is made to make a connection to a DNO. We understand that a number of DNOs are providing pre-application advice to bodies such as Local Authorities in matters such as constraints and where connections could be most readily or cheaply made. It may be that the DNOs are currently the best body to provide this advice and information given their knowledge of current capacity on their networks and future developments expected on a network. However, as data on networks are increasingly provided openly to other parties via websites or other portals, those third parties may also be in a good position to provide valuable advice on the siting of connections. As such, we recommend that the CiCCOP is reviewed to ascertain whether competition could be introduced at an earlier stage, i.e. at the pre-applications stage, so that third parties could have an opportunity to compete to provide such connections advice. It will be valuable to capture the opinions of those that currently receive this advice without charge as well as the views of those that could be potential competitors to assess the merits of introducing competition at this earlier stage. There may also be other opportunities for competition that could arise with the wider open provision of DNO data and it may be valuable to consider this aspect beyond connections competition.