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.
Gemserv’s wide-ranging expertise, including 15 years as a central industry body, means that we are involved in many of the major policy developments and industry initiatives across the energy sector. This includes in our capacity as a code administrator for the Master Registration Agreement (MRA) which oversees electricity switching practices and supports the settlement processes under the Balancing and Settlement Code (BSC); for the Smart Energy Code (SEC) which sits at the heart of the implementation of GB smart metering; and for the iGTUNC the Independent Gas Transporters network code.
Consequently, we are at the forefront of addressing the day-to-day operational challenges and issues with which all energy market participants are wrestling and help to design and deliver solutions that achieve the ‘effective and efficient’ aims of the market.
We highlight that the challenge of driving forward with reforms on this scale, whilst trying to keep down energy costs, is a significant endeavour. Indeed, the UK Government commissioning its ‘Cost of Energy Review’ – headed by Dieter Helm, with terms of reference that include transforming the power sector and creating energy policy with ‘minimum cost and without imposing any further costs on the exchequer’, gives a clear emphasis that the cost to consumers should be a fundamental driver.
With respect to the reuse of existing systems, in this case UK Link, our starting position is to ensure that, given the need to drive transformational reform against a consumer led agenda, we move forward subject to three core principles:
- Introduce competitive pressures to drive efficient practices, costs, benefits and innovation;
- Examine how existing investment can be leveraged to support change before seeking out new investment; and
- Evaluate new technologies against other options to ensure that there is sufficient confidence of delivering a more effective outcome in the longer term without unduly disrupting today’s competitive markets.
Our response to the ‘UK Link and the proposed Central Switching Service’ consultation is therefore framed by these drivers and included as an appendix.
To read the full consultation please click below.