Energy Demand Research Centre’s response to DESNZ & Ofgem consultation on: Heat networks regulation - implementing consumer protections

Consultation Response November 2024

Introduction

Prof Sara Walker answered the following questions from ODESNZ & Ofgem consultation:

  1. With reference to proposed consumer protection measures in this consultation, are there any measures that in your view are not relevant to heat networks using shared ground loops and individual consumer heat pumps? If so, what measures and why?
  2. In applying consumer protections to a heat network using shared ground loops and individual consumer heat pumps, in your view should there be
    differentiation between networks which charge a fee to access the loop, networks that do not charge a fee, and networks that utilise other ambient heat sources in addition to boreholes?
  3. Do you agree or disagree with the proposed approach to ‘supply to premises’ conditions?
  4. Do you have any views on the high-level fair pricing framework discussed in the Fair Pricing section and in Annex 3 of this document?
  5. Do you agree or disagree with our proposed overall approach to vulnerability, adopting the existing Ofgem definition for gas and electricity consumers but combining this with targeted protections for heat network consumers, where needed, through the authorisation conditions?
  6. Do you agree or disagree with our proposal to explore options to mitigate the impact of unrecoverable debt arising from prohibitions on disconnecting consumers, or installing pre-payment meters, for protected consumers? If yes, please provide any views you may have on approaches for doing so.
  7. Do you agree or disagree with our proposed approach to apply Overall Standards of Performance to heat networks operating on a not-for-profit business model?
  8. Do you agree or disagree with the proposals for including additional information on consumer bills? If you agree, what timescales could you reasonably implement these changes?
  9. Do you agree or disagree that we should further explore the proposal on unbundling heat from other service charges, noting this may require legislative change to be implemented? Do you have any views on options 1, 2 and 3?
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