Citizens Advice response to Department for Energy Security and Net Zero & Ofgem Energy Code Reform Consultation on Code Manager Licence Conditions and Code Modification Appeals to the Competition and Markets Authority
We welcome the opportunity to respond to this important consultation which provides proposals for key code licence conditions for code reform as well as appeal rights. We are largely in agreement with the proposals and the preferred options proposed by the Department for Energy Security and Net Zero and Ofgem. In particular, we support the openness and transparency objective and believe that this objective should be cascaded throughout the operations of the codes including the activities of the Stakeholder Advisory Forums, Performance Assurance Boards, and any similar sub-committees.
We would expect that stakeholder feedback, through annual surveys, is given sufficient weight when assessing the minimum acceptable performance standard. We would also recommend that the survey is conducted by an independent company or body rather than the Code Manager directly. A minimum set of standardised questions across all Code Managers would enable direct comparison.