Citizens Advice response to the Ofgem consultation on the preliminary Strategic Direction Statement and governance arrangements for industry codes
We believe that this consultation is a useful contribution to gain views for the format and content of the preliminary Strategic Direction Statement (SDS) and for the continuing development of the code manager governance model. We are supportive of the direction of these consultation proposals including the three time horizons, the emphasis on prioritisation, consistent criteria across codes for prioritising modifications, the principles-based condition for cooperation, and for stakeholder engagement.
We are particularly pleased to see the strong consumer emphasis of Objective 2 of the SDS to ‘Ensure high quality of focus’ and we welcome its emphasis on protecting domestic and non-domestic consumers, and consumers in vulnerable situations.
Our chief recommendations are:
That there is sufficient resource built into the modification process to enable standard priority modifications (which may only affect one or a few parties but are of overall consumer benefit) to be able to proceed alongside the urgent or high priority modifications. We are concerned that if only the highest priority modifications are acted upon that there may be a detrimental effect on industry participation for innovation or competition which may not be in consumers’ wider interests.
For a right of appeal to allow a code party and consumer advocacy groups to challenge a modification prioritisation.
For better cross-code coordination. This could be led by Ofgem or through a body such as an evolved and reinvigorated Code Administration Code of Practice (CACOP) or a wider remit Cross-Code Steering Group.