This submission was prepared by the Consumer Futures team within Citizens Advice and Citizens Advice Scotland (The Citizens Advice Service). It has statutory responsibilities to represent the interests of energy consumers in Great Britain and we welcome the opportunity to respond to this consultation.
In our view, the Draft Determination represents a mixed outcome for consumers. While there are positive elements we continue to be concerned that the DNOs will be over-remunerated under RIIO-ED1. We ask therefore that Ofgem clarifies the assumptions that underpin the headline figures in the Draft Determination and that reporting arrangements meeting this description are implemented in time for the commencement of RIIO-ED1 in April 2015.
We also take this opportunity to comment on some specific aspects of the Draft Determination that we have not addressed in detail in earlier submissions, including forecast savings from smart metering and grids, and losses.