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Publication date:November 2019
Citizens Advice Scotland (CAS) believes it is more important to get the smart meter rollout right than it is for it to be rushed through to arbitrary deadlines, and we have long been concerned that the 2020 smart meter deadline was so unrealistic that it risked having a negative effect on consumers. In June 2016 we therefore published a report that called for the smart meter rollout to adopt an interim target of 80% smart meter coverage by the end of 2020, with 100% coverage achieved no later than the end of 2025. We reiterated this call in August 2018, and so we welcomed the UK Government’s September 2019 announcement that the smart meter rollout is to be extended to the end of 2024.
This new-found pragmatism provides an opportunity for a review of the targets, incentives and penalties to which energy suppliers will be exposed as the smart meter rollout progresses over the next 5 years. However, it must also be acknowledged that there remain multiple technical barriers to the universal rollout of smart meters, particularly in remote rural areas and for many Scottish households that use traditional electric storage heaters as the primary form of space heating.
These constraints lead CAS to be concerned that consumers reliant on electric heating in Scotland will be among the very last in GB to benefit from the smart meter rollout. Indeed, under current proposals we believe that it would be possible for electricity suppliers to comfortably exceed the proposed post-2020 smart meter targets without a single Scottish consumer with traditional electric heating having benefited from the rollout. This risks placing the costs of maintaining the traditional meter network onto a relatively small customer base, increasing prices for a group of consumers where a majority (52%) already struggle to afford to heat their homes to an acceptable standard.
CAS does not underestimate the significant challenges required to overcome these issues, but we are equally clear that the smart meter policy framework and the regulation of the retail energy market post-2020 must not unfairly burden consumers with additional costs they have no opportunity to avoid. We therefore believe that there may be a need to provide short-term protection for consumers whose ability to access the benefits of smart meters is restricted by the industry's readiness to provide them with suitable metering equipment. We also consider that suppliers could be better encouraged to deliver a market-wide smart meter rollout in all areas of GB if the proposed minimum coverage level were to apply separately in each electricity distribution network area.
While CAS supports proposals to move away from the “all reasonable steps” obligation that currently governs suppliers’ smart meter engagement programs, we are also cautious about the impact of holding suppliers to binding, linear annual targets given the technical barriers referred to above. The Citizens Advice network in Scotland already hears the concerns of consumers who have felt pressured into accepting a smart meter by their energy supplier, and even of instances where attempts to install smart meters have been made by domestic energy supply licence holders that are not the registered supplier at the property concerned. This suggests that while the imposition of installation targets backed by financial penalties for non-compliance may be driving the pace of the smart meter rollout, such targets may adversely impact consumers’ experience of smart meter installation and could jeopardise levels of engagement with the planned transition to a smarter energy future. We believe that suppliers may already be suitably incentivised to encourage their customers to embrace smart meters, and we therefore urge Ofgem to place its post-2020 focus on the enforcement of a high quality customer journey throughout the energy transition.Spotlight: -
Publication date:November 2019
In June 2018 the energy regulator, Ofgem, consulted on proposals to introduce a series of new Guaranteed Standards of Performance on all domestic gas and electricity suppliers in GB. These were to place a service level requirement on suppliers to provide consumers with an automatic and pre-defined level of compensation when problems with switching supplier occur. Following feedback from the energy industry and its stakeholders, the first 3 of these new Guaranteed Standards of Performance for Switching were introduced on 1 May 2019.
Following further work in this area, in September 2019 Ofgem consulted on the introduction of a second phase of the Guaranteed Standards of Performance for Switching. These would provide an automatic and pre-defined level of compensation to consumers where a change of supplier takes longer than 21 calendar days to complete; where a Final Bill is not issued by the losing supplier within 6 weeks of a switch; and where a consumer is erroneously transferred to a new supplier.
CAS supports Ofgem’s objectives in its proposals to introduce additional Guaranteed Standards of Performance for Switching. However, in our response to this consultation we detail concerns with some of the proposals as they currently stand.
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Publication date:September 2019
The Capacity Market arose from the UK Government’s Electricity Market Reform in 2014 and is designed to provide assurance that electricity supply can continue to meet demand where, for example, demand peaks coincide with periods of reduced renewable electricity generation.
After being selected on price through a reverse auction process, Capacity Market participants undertake to reduce stress on the electricity system, either by bringing additional generating plant online or by deploying technologies that reduce electricity demand.
To date, the Capacity Market auctions have favoured the provision of additional generating capacity, but this has often been reliant on relatively carbon-intensive forms of electricity generation which run counter to the Government’s ambitions on climate change. In July 2019, BEIS therefore consulted the energy industry and its stakeholders on how it might create new markets for energy efficiency in the electricity system such that it could become a viable alternative to the provision of additional generating capacity or electricity network reinforcement as a means of meeting peak demand.
In our response to this consultation, CAS observes that:
- The Capacity Market may yet prove not be an appropriate route by which to encourage investment in energy efficiency in the electricity market. However, the results of the Electricity Demand Reduction pilot do not definitively show that that energy efficiency is unable to compete in a Capacity Market, and more evidence is therefore needed before firm conclusions can be made.
- The design of Capacity Market should be revised to allow the whole system costs and benefits of a given intervention to be considered when assessing the value of competing bids. This would help to address the competitive disadvantage that electricity demand reduction technologies such as demand side response, flexibility services and energy efficiency face in the Capacity Market, where the carbon intensity of a given intervention is currently not considered.
- Reform of the Capacity Market should seek to take a whole system view of the whole life costs of a given intervention, where competing technologies such as energy efficiency and storage or flexibility services are also seen as complementary to one another.
- The Energy Efficient Scotland program and the development of Local Heat and Energy Efficiency Strategies presents a sizeable opportunity to leverage Capacity Market funding for energy efficiency as a form of electricity demand reduction.
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Publication date:September 2019
This is CAS’s response to the Call for Evidence on the Annual Energy Statement. We believe that while Scotland is likely to miss its target of achieving 11% of heat demand coming from renewables by 2020, there are actions the Scottish Government can take to ensure that it remains on course for achieving net zero by 2045, including;
› Boosting public buy-in by stepping up practical and financial support for consumers
› Driving technological innovation
› Reducing the cost of renewables
These measures will help to address what CAS believes are the key risks and threats to achieving the 2045 target:
› the initial cost of moving to renewable heat sources
› the lack of public awareness and buy-in to the scale of the change needed
› the quality of installations and access to redress when things go wrong
› the lack of advice and guidance on how to properly use low carbon heating systems to best effect
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Publication date:September 2019
CAS welcomes Ofgem’s proposals to improve outcomes for consumers who experience self-disconnection and self-rationing. We have identified a number of priorities:
- The standardisation of friendly credit dates and hours, where technically feasible
- Improvements to emergency credit provision, which maintains flexibility, but allows for the maintenance of supply in a reasonable worst case scenario
- The removal of barriers to discretionary credit, which maintains protection from excessive debt, but enhances consumer choice
- Improvements in how suppliers communicate with their prepayment customers, for e.g. as regards the seasonal accrual of standing charges
- The formalisation of Ofgem’s Ability to Pay principles in the licence code
- Utilisation of the full suite of smart functionality, for e.g. suppliers switching meters to credit mode to maintain supply
- Viable alternatives to prepayment, for e.g. clarification on the future of Third Party Deductions for energy (Fuel Direct)
- The extension of fuel voucher schemes (fuel credits)
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Publication date:September 2019
This is CAS’s response to the Energy Efficiency (Private Rented Property) Regulations 2019. We welcome mandatory standards of energy efficiency in the private rented sector, provided that:
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Publication date:September 2019
CAS has responded to BEIS’ Hydro Benefit Replacement Scheme (HBRS) and Common Tariff Obligation (CTO) consultation. Both are subject to a statutory 3-year review and are designed, respectively, to subsidise the cost of electricity distribution in the North of Scotland to avoid disproportionately higher distribution network costs for consumers vs. those charged in the rest of GB; and to prevent domestic suppliers from offering less favourable terms to remote rural and island communities in the North of Scotland than they do to comparable consumers located elsewhere within the North of Scotland electricity distribution network operator region.
The HBRS imposes a levy on every electricity consumer in GB. For a typical dual fuel domestic consumer, this equates to about £1 per annum. To date, however, the additional costs of electricity distribution in the Shetland islands has been fully met by consumers in the North of Scotland. It is proposed that this will change and will instead be distributed throughout GB.
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Publication date:August 2019
CAS welcomes the opportunity to respond to the ENAs consultation. We think that the consultation raises issues that need to be quickly addressed as the electricity flexibility market develops.
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June 2019Publication date:June 2019
This is CAS's response to the Scottish Government's consultation on the Energy Efficient Scotland programme.
Energy Efficient Scotland (EES) is an ambitious Scottish Government programme which aims to improve the energy efficiency of Scotland’s housing stock over the next 20 years in a bid to reduce carbon emissions and fuel poverty. One of the proposed strands of the programme is the regulation of minimum standards of energy efficiency in both rented and owner occupied domestic properties. This would take the form of mandatory Energy Performance Certificate (EPC) standards to be achieved by respective sectors by a target date. This consultation seeks views on whether the Scottish Government should bring forward the date for all owner occupied homes to be EPC Band C or above by 2030, where technically feasible and cost effective. It also seeks views on the implementation of regulations for the private rented sector.
The accompanying research report summarises the results of an omnibus survey that we commissioned in March 2019. The aim was to: better understand levels of awareness about EPCs; what homeowners are currently doing, if anything, to upgrade the energy efficiency of their homes; what would motivate homeowners to install more energy efficiency measures; and how Scottish homeowners and renters feel about potential regulation of energy efficiency.
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June 2019Publication date:June 2019
This is CAS's response to the Scottish Government's consultation on the future of low carbon heat for off-gas buildings.
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Energy Advice in Detail: Energy issues brought to the Citizens Advice network in Scotland in 2017-18
Publication date:June 2019This report details the energy issues advised on by the Citizens Advice network in Scotland in 2017-18.
The data shows that of the three main strands of the network, the majority of energy-related advice
in Scotland continues to be provided by Scottish Citizens Advice Bureaux, accounting for 92% of the advice provided
in 2017-18.This reflects the complementary nature of the Citizens Advice network which in 2017-18 included:
- Citizens Advice Bureaux which primarily provide advice on complex interrelated issues;
- the Extra Help Unit undertakes specialist case work on behalf of vulnerable consumers, often in urgent need of assistance; and
- the Citizens Advice Consumer Service has a statutory remit to deliver first tier advice.
In 2017-18, a total of 41,233 energy issues were advised on across the whole Citizens Advice network in Scotland.
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CAS responds to new Commission's call for evidencePublication date:May 2019
The Scottish Government has established the Infrastructure Commission for Scotland to provide independent, informed advice on the creation of a 30-year infrastructure strategy to meet the country’s future economic growth and societal needs. To support this, the Commission issued a call for evidence.
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Publication date:March 2019People can be vulnerable at different stages in our lives. When we are, we are likely to need water, light and heat more than ever. In this country we are entitled to receive extra help, such as receiving additional support during a power cut. However receiving this support relies on people being registered for it.
In 2018, CAS commissioned Ipsos MORI Scotland to investigate the experiences and perspectives of Scottish consumers in vulnerable situations with regard to additional support provided by essential service providers, and how could the customer experience and process of registering across sectors for additional forms of support be improved.
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Publication date:March 2019
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.
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Publication date:January 2019
CAS responded to the UK Parliament's Business, Energy and Industrial Strategy Committee energy efficiency inquiry.
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Publication date:December 2018Spotlight:
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Publication date:December 2018
Citizens Advice Scotland (CAS) welcomes the opportunity to contribute to this important discussion on the future of housing in Scotland. In 2017/2018, Scottish Citizens Advice Bureaux (CAB) advised clients on 46,777 housing issues, making housing the fourth largest area of advice provided by the network. This response is shaped by our evidence on the many and varied housing issues that CAB clients face, as well as by our Consumer Futures statutory responsibilities.
Stressed About Debt? High costs of energy, food and fuel mean that many people are finding it impossible to keep up, worrying about debt or falling behind on bills. The Citizens Advice network in Scotland is here for you, with free, confidential and impartial advice in a variety of ways.