Citizens Advice response to Ofgem Establishing a harmonised prioritisation process in the Industry Codes: statutory consultation
We support Ofgem’s code reform agenda including harmonising prioritisation criteria and processes across the codes. We agree that allocating certain modifications to a high priority level is appropriate to rapidly achieve aims relating to the Strategic Direction Statement (SDS) and other important matters. However, we believe that there also needs to be a focus upon ensuring that there are sufficient resources within the Code Managers and Ofgem to allow for standard priority modifications to proceed in a timely manner. We are aware of existing delays in decisions for some non-urgent modifications in some codes (e.g. outstanding decisions in Connection and Use of System Code from 2024). There is a risk that there may be unacceptable delays for decisions for standard priority modifications either within the Code Manager or within Ofgem if there is insufficient capacity to manage both high priority and standard priority modifications. Such lower priority proposals may still be valuable for consumers and industry parties in matters such as increasing competition or raising consumer standards and such modifications should be moved forward without undue delay.
We do not support allowing differences in code prioritisation procedures for the Retail Energy Code (REC) and Smart Energy Code (SEC), and for different appeal processes across various codes. It is not clear why certain codes should have different processes when compared to others and there does not appear to be strong justification for these differences. The aim of this code reform should be consistency in process unless there is an overwhelming reason for differences. We believe that harmonisation of processes in prioritisation and appeals would avoid complexity and confusion. Maintaining differences in process would waste the opportunity of this code reform to align all the codes and would set a precedent for further divergence between codes in the future.