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In June 2018 the energy regulator, Ofgem, consulted on proposals to introduce a series of new Guaranteed Standards of Performance on all domestic gas and electricity suppliers in GB. These were to place a service level requirement on suppliers to provide consumers with an automatic and pre-defined level of compensation when problems with switching supplier occur. Following feedback from the energy industry and its stakeholders, the first 3 of these new Guaranteed Standards of Performance for Switching were introduced on 1 May 2019.

Following further work in this area, in September 2019 Ofgem consulted on the introduction of a second phase of the Guaranteed Standards of Performance for Switching. These would provide an automatic and pre-defined level of compensation to consumers where a change of supplier takes longer than 21 calendar days to complete; where a Final Bill is not issued by the losing supplier within 6 weeks of a switch; and where a consumer is erroneously transferred to a new supplier.

CAS supports Ofgem’s objectives in its proposals to introduce additional Guaranteed Standards of Performance for Switching. However, in our response to this consultation we detail concerns with some of the proposals as they currently stand.

In this response, Citizens Advice Scotland lays out our support of the broad aims of the principles within the policy statement, but urge that much more must be done to strengthen consumer protection and ensure that communities are involved in the process in an inclusive, sustainable way that meets their needs. 

The Capacity Market arose from the UK Government’s Electricity Market Reform in 2014 and is designed to provide assurance that electricity supply can continue to meet demand where, for example, demand peaks coincide with periods of reduced renewable electricity generation.

After being selected on price through a reverse auction process, Capacity Market participants undertake to reduce stress on the electricity system, either by bringing additional generating plant online or by deploying technologies that reduce electricity demand.

To date, the Capacity Market auctions have favoured the provision of additional generating capacity, but this has often been reliant on relatively carbon-intensive forms of electricity generation which run counter to the Government’s ambitions on climate change. In July 2019, BEIS therefore consulted the energy industry and its stakeholders on how it might create new markets for energy efficiency in the electricity system such that it could become a viable alternative to the provision of additional generating capacity or electricity network reinforcement as a means of meeting peak demand.

In our response to this consultation, CAS observes that:

• The Capacity Market may yet prove not be an appropriate route by which to encourage investment in energy efficiency in the electricity market. However, the results of the Electricity Demand Reduction pilot do not definitively show that that energy efficiency is unable to compete in a Capacity Market, and more evidence is therefore needed before firm conclusions can be made.
• The design of Capacity Market should be revised to allow the whole system costs and benefits of a given intervention to be considered when assessing the value of competing bids. This would help to address the competitive disadvantage that electricity demand reduction technologies such as demand side response, flexibility services and energy efficiency face in the Capacity Market, where the carbon intensity of a given intervention is currently not considered.
• Reform of the Capacity Market should seek to take a whole system view of the whole life costs of a given intervention, where competing technologies such as energy efficiency and storage or flexibility services are also seen as complementary to one another.
• The Energy Efficient Scotland program and the development of Local Heat and Energy Efficiency Strategies presents a sizeable opportunity to leverage Capacity Market funding for energy efficiency as a form of electricity demand reduction.

This policy report summarises findings and recommendations from our research into the complaints process for post and parcel companies. 

CAS commissioned interviews with a number of delivery companies, and found that many are falling behind the Universal Service Provider Royal Mail when it comes to consumer complaints procedures.

Citizens Advice Scotland has called for phone, broadband and pay-TV providers to recognise that vulnerable consumers need extra support in accessing these services.

In a response to a consultation by Ofcom which is seeking to provide guidance to providers on treatment of vulnerable consumers, CAS calls for an inclusive approach which widens the definition of vulnerability to include rurality, and which recognises that consumers can be vulnerable at different times in their lives.

Since the roll out of Universal Credit (UC) began, CAS has repeatedly raised concerns about fundamental elements of the design and delivery of the UC system.

Citizens Advice Bureaux (CAB) data, including Citizen Alerts (cases from local CAB), have shown the key problem elements of UC to be; the five week wait for first payment, the digital by default system, direct deductions from payments and increasing rent arrears caused by the cycle of payment in arrears.

Andrew Scobie of Perth CAB has carried out a qualitative study to explore how third parties, specifically creditors and health professionals, are responding to the needs and circumstances of indebted citizens with mental health issues.