Citizens Advice response to consultation on the RIIO-2 Re-opener Guidance and Application Requirements Document
This submission responds to the Ofgem RIIO-2 draft re-opener guidance document consultation.
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.
Network companies are also required to provide evidence of the stakeholder engagement relating to the re-opener project including evidence relating to considerations by User Groups, Customer Engagement Groups or other similar stakeholder panels. This stakeholder engagement may relate to activities during the RIIO-2 business planning process as well as subsequently.
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.