Energy UK response to Ofgem’s Energy code reform: implementation consultation

Executive Summary

Some of the most important points in our response are:

➢ It is vital that the appeal process via the CMA on economic grounds be retained
alongside judicial review, and the right to appeal is retained during the transition.
➢ A Net Zero code objective would be a welcome addition to the existing objectives, but
does require careful consideration of interdependencies across the code objectives.
➢ The Strategic Direction Statement (SDS) should be aligned with the Strategy and
Policy Statement (SPS) for energy policy, with progress reported as part of the
annual reporting requirement for Ofgem under the SPS.
➢ Ofgem should establish how it intends to deliver the proposed change processes,
including how to resource this work while continuing to progress existing
workstreams, and how this work will be aligned with wider work to reform
connections processes, to establish the FSO, and to progress critical ongoing code
modifications.
➢ Where codes are consolidated, Ofgem should consider how to ensure that the
Stakeholder Advisory Forum (SAF) is able to address both commercial and technical
issues, particularly in the consolidation of Grid Code, STC, SQSS and Distribution
Codes.

If you have any questions about this response or wish to engage with Energy UK and its
members, we would welcome further engagement.

Charles Wood
Deputy Director
charles.wood@energy-uk.org.uk
+44 (0)20 7024 7636

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