Citizens Advice response to Ofgem working paper on future enabling the market-wide settlement reform Target Operating Model (TOM)
In our response to this working paper, we agree with Ofgem that the future operating model for electricity settlement has to facilitate or at least not impede developments we can foresee in the energy market, including consumers having multiple suppliers and taking part in energy trading platforms.
Considering future potential changes to the metering and settlement system mentioned in the Ofgem paper, we:
pointed out that if sub-metering was to become a more wide-spread feature of the energy market, that we would like to see consumer rights strengthened in this area;
voiced our concerns in relation to consumer access device data, which collect even more detailed and therefore personal data than smart meters. Their installation needs explicit consent, informed consent from consumers;
pointed out the need to efficiently allocate system costs in an accurate enough manner to avoid undue cross-subsidisation between consumer groups;
agree with Ofgem that using unmetered settlement arrangements for public electric vehicle chargers it not sustainable in the future, and is an example of where undue cross-subsidisation would take place.