Citizens Advice response to the Ofgem consultation on the Market Facilitator Delivery Body

Citizens Advice response to the Ofgem consultation on the Market Facilitator Delivery Body 102 KB  

We support the introduction of an independent market facilitator body to drive forward the development of the flexibility market. We have no overriding preference for whether the Future System Operator (FSO, now named the National Energy System Operator (NESO)) or Elexon is appointed as the market facilitator body as we believe both entities could perform the role adequately. It may be simpler and quicker on governance grounds for the body to be the FSO.

The market for flexibility will introduce new participants that may be less familiar with the energy market (e.g. community energy groups, housing groups, new domestic aggregators, etc.) and which are unknown to the FSO or Elexon. Whichever entity is awarded the market facilitator role, there will be a need to have a focus upon developing wide and robust stakeholder engagement beyond traditional industry participants. 

A high focus on consumer benefits will need to be a priority and we would recommend a requirement for a consumer duty for the market facilitator if Elexon is selected (as FSO will have a consumer duty). Strong representation from consumer and smaller community groups is needed in stakeholder advisory and governance arrangements to ensure that the consumer voice is adequately heard. Governance arrangements should align with the code reform proposals, where possible, to ensure consistency, along with ensuring appeal rights on decisions.

Ofgem should ensure that the market facilitator body transitions seamlessly from the Energy Networks Association Open Networks (ON) project and that there is no slowing of progress in market development while this transition occurs .  

There was no mention within the consultation about peer-to-peer trading. The focus appears to be directed only at the FSO and DNOs as the sole buyers of flexibility. It is important to ensure that the market facilitator role considers the needs of peer-to-peer market participants. A deeper and broader market of both buyers and sellers will ensure competitive and fair pricing as well as ensure that net zero goals are reached as rapidly as possible.