Executive summary
The implementation of a fair pricing framework is essential to consumer protection. Unfair billing practices can have an adverse impact on the reputation of heat networks and damage investor confidence within the sector, threatening the growth of the industry. Energy UK supports and welcomes the efforts of Ofgem in the development of these guidelines to ensure both customers and investors are supported.
The key principles highlighted in this response to achieve effective fair pricing and cost allocation guidance are:
- Energy UK supports the adoption of an outcome based and iterative approach where guidelines are regularly reviewed, supported by evidenced consumer detriment and robust policy development.
- Ensure continued alignment with the Heat Network Technical Assurance Scheme (HNTAS) and other regulatory measures.
- Guidance should provide certainty and transparency for industry. This will aid commercial viability and investment decisions, particularly as pricing depends on long-term contractual arrangements.