Consultation Responses

Consultation on Cost of Energy Review

Gemserv welcome the opportunity to provide evidence with respect to the Helm Energy Review.

Our response draws heavily from the unique insights and energy market experience in our capacity as a central code governance body spanning over 15 years across electricity and gas. Gemserv’s consultancy services work covers a wide range of energy policy and regulatory aspects, including: price controls, customer switching, smarter markets, assurance, information and cyber security. We are at the heart of the fundamental market reforms already underway and experience first-hand the challenges and the opportunities that arise across the entire energy sector.

Consultation on Building a Market for Energy Efficiency

Gemserv is integral to the operation of many Government and industry led energy efficiency and renewable programmes, including the Microgeneration Certification Scheme (MCS), the Green Deal and the Biomass Suppliers List (BSL), which supports the Renewable Heat Incentive (RHI).

We have responded to the Department for Business, Energy and Industrial Strategy’s consultation on the energy efficiency market. Gemserv have responded to a number of their specific questions in the attached Annex, based on our experience and where we think we can add value, and have outlined below the key points we wish to make.

Consultation on Green Deal Framework

Gemserv has been involved in the Green Deal since its inception, operating three central roles. Through this Gemserv welcomed the opportunity to respond to Ofgem’s consultation on the Green Deal Framework.

Within our response we answer a number of Ofgem’s specific questions and outline our key points within the consultation.

Consultation on Proposed New Switching Arrangements

Gemserv are responding to Ofgem’s consultantion on the Proposed New Switching Arrangements. In our response we have responded to a number of your specific questions in the attached Annex and outline below the key points we wish to make.

Consultation on the Security of Network and Information Systems (NIS) Directive

Gemserv are responding to a consultation the Government are running on their plans to implement the Security of Network and Information Systems Directive (“NIS Directive”).

As our reliance on technology grows, the impact of failure in those systems and the opportunities for those who would seek to compromise our systems and data increase. Responding to this threat and ensuring the safety and security of cyberspace is an essential requirement for a prosperous UK economy. We need to secure our technology, data and networks in order to keep our businesses, citizens and public services protected.

UK Link and the proposed Central Switching Service

Gemserv welcome the opportunity to respond to Ofgem’s UK Link and the proposed Central Switching Service consultation.

The challenges faced by all market participants are heavily contextualised by the unprecedented energy market transformation now taking place, and the proposed switching reforms are a significant dimension to this.

Moving to Reliable and Fast Switching: Switching Programme Business Case including Design Baseline 1

Gemserv are responding to Ofgem’s switching programme request for information. Our vision is “ensuring complex markets work for everyone’s benefit”, and the proposed solution as explained in our response, is seeking to simplify the solution, making markets work effectively, to ensure the solution delivers the required outcomes (i.e. it works for everyone), and is cost efficient.

Industry Code Governance; Initial Consultation on Implementing the Competition and Markets Authority’s recommendations

We welcome the opportunity to respond to the initial consultation on Implementing the Competition and markets authority’s recommendations. We have responded to a number of your specific questions.

In our previous responses (e.g. to the CMA), we explained there are a number of important considerations to take into account as we move forward with respect to the proposed remedies, noting in particular the ‘Recommendations’ which propose an Ofgem Strategic Direction, Consultative Board, and in particular the Recommendation that seeks to licence code administration and delivery services.

Leaving the EU: Implications for UK Climate Policy Inquiry

Gemserv is responding from the perspective of a UK based independent specialist utilities consultancy firm, heavily involved in the UK energy market and environment sector. Gemserv has been at the heart of the UK energy market since 2002, and in particular, manages central market industry codes, agreements and systems such as the Smart Energy Code Administrator and Secretariat (SECAS), the assurance provider for the Retail Market Design Service (RMDS) in Ireland, and as the administrator for the Microgeneration Certification Scheme (MCS).

Leaving the EU: Implications for UK Energy Policy Inquiry

Gemserv is responding from the perspective of a UK based, specialist utilities consultancy firm. Although we conduct information security work internationally, we are also heavily involved in the UK energy market.

Gemserv has been at the heart of the UK energy market since 2002, and in particular, managing central market industry codes and agreements and systems. Industry codes play a fundamental role with respect to interoperability across the Great British energy market. Legislative and policy changes can have a significant impact on these codes, and therefore on how market participants interact with each other.