Citizens Advice Scotland (CAS) uses research and evidence to put consumers at the heart of policy and regulation in the energy, post and water sectors in Scotland. CAS is the Scottish consumer advocate on energy network issues and work closely with Citizens Advice England and Wales in this area.
Our response focuses on areas where we have had involvement with Ofgem working groups, CEGs and stakeholder groups. The majority of our detailed response relates to specific proposals for GD2 and in particular questions related to customer and social.
Please find a summary of our key points below:
1) CAS welcomes Ofgem’s approach for RIIO 2 - with a focus on driving consumer value and protecting against excessive network company returns.
2) We support Ofgem’s approach to giving consumers a stronger voice (such as through CEGs) and would encourage stakeholder engagement to be incentivised for both ET2 and GD2.
3) We agree with Ofgem’s focus on support for vulnerable customers and in particular the proposed combined vulnerability package for GD2.
4) We encourage Ofgem to ensure that innovation continues to be a strong component of the RIIO process – and that projects with social benefit should be a particular focus for innovation funding.
5) We support the proposal for bespoke PCDs and ODIs which may help to ensure that regional variation in customer needs and wants are deliverable through the price control – but recognise the need to ensure that these are tested with customers and through CEGs.