Citizens Advice Scotland (CAS) uses research and evidence to put consumers at the heart of policy and regulation in the energy, post and water sectors in Scotland. We work with government, regulators and business to put consumers first, designing policy and practice around their needs and aspirations.
CAS is the Scottish consumer advocate on energy network issues. Although separate organisations, we work closely with Citizens Advice England and Wales in this area. Our response below focuses on Scottish specific points which we believe are important considerations for the TCR.
Summary of key points:
1) CAS welcomes Ofgem’s work on the TCR and recognises the need for change
2) CAS welcomes the broad re-balancing of charges between the domestic and non-domestic sector
3) We raise a number of significant concerns with the fixed charge method that is being proposed and in particular the effect it may have on low income households – which has potential to exacerbate fuel poverty in Scotland.
4) Further analysis and consumer research is needed to understand distributional impacts within the domestic sector in Scotland
5) CAS believe that households in the North of Scotland who face the largest impact from the proposed changes need appropriate protection
6) CAS does not think that Economy 7 users should face higher residual charges than other domestic users
7) The impact from the review of ‘access and forward looking charges’ needs to be better understood before decisions on ‘residuals’ are made