Energy UK response to Ofgem Consultation on the preliminary Strategic Direction Statement and governance arrangements for industry codes

Executive summary

Energy UK welcomes the publication and the intent of this Strategic Direction
Statement (SDS) and recognises the critical importance of strategically progressing
energy code reforms to ensure this work does not impact wider workstream delivery.
The proposals within this consultation, and the engagement and work delivered by
Ofgem to date, are broadly welcome, with some concerns remaining.

• The proposed Standard Licence Condition (SLC) requiring parties to ‘cooperate’
  with code changes remains concerning. Existing SLCs require suppliers to
  comply with code changes, implicitly ensuring that suppliers engage with codes
  given their importance to their business and operating models. There is no
  evidence provided in this consultation to demonstrate where supplier nonengagement has impacted customers or the industry and no detail on how the
  SLC would work in practice, with potential increases in administrative burden as
  suppliers are compelled to cooperate with a much wider range of changes.
• More detail is needed regarding: a) concrete proposals on prioritisation; b) the
  nature and timing of code reform processes; c) how reforms will be prioritised to
  best deliver on Ofgem’s statutory duties; d) resourcing of code bodies and Ofgem
  to ensure this work does not impact the delivery of other workstreams.
  These areas should be worked through holistically and collaboratively with industry.
  Energy UK and its members welcome continued engagement on shaping and
  implementing this critical change process.

Tobias Burke
Policy Manager
Tobias.Burke@energy-uk.org.uk

Charles Wood
Deputy Director
Charles.Wood@energy-uk.org.uk