Public

Citizens Advice Scotland (CAS) believes the Universal Credit (UC) system must change if the benefit is to work for all citizens across Scotland, and the rest of the UK. By ‘work’ CAS means the UC system should not cause financial destitution or debt, should be accessible to everyone and should support people who are in work.

This briefing paper outlines the scale of the challenge to improve the energy performance of Scotland’s housing stock. It presents CAS’ estimate of how much it will cost to raise the energy performance of all homes in Scotland to at least an EPC C by 2040 (EPC B for social sector homes) in line with the Scottish Government’s target under Energy Efficient Scotland (EES).

CAS welcomes the proposals for ECO3. The ECO scheme has helped deliver energy efficiency measures to vulnerable consumers in two other phases and we were pleased to see that BEIS and Ofgem are expanding consumer protections in this third iteration. In particular, we are pleased to see the incorporation of Trustmark into ECO3 to certify suppliers.  

Citizens Advice Scotland welcomes the opportunity to respond to this consultation. It is important that we recognise the role that all bodies and sectors have to play in achieving the new and ambitious climate change targets that were passed in the Climate Change Bill in September 2019. 

It is, however, imperative that the Scottish Government properly supports public bodies to meet any new duties or roles. It is important that public bodies are able to continue to provide the same (or higher) standard of service to citizens without inadvertently or intentionally passing on the cost of achieving emissions reductions to the very citizens they are trying to support.

The energy regulator, Ofgem, publishes data on the consumption of gas and electricity by typical domestic consumers in GB. These Typical Domestic Consumption Values become industry standards and are used in a variety of different ways by energy suppliers, Price Comparison Websites, and the media. They have also become the benchmark annual consumption value used by Ofgem when it sets the prepayment and default tariff price caps.

The Typical Domestic Consumption Values are based on the total domestic consumption of gas and electricity in GB over a 2-year period and are subject to biennial review.

Having last been reviewed in 2017, Ofgem published its latest review of the Typical Domestic Consumption Values in an open letter to the energy industry and its stakeholders on 18 October 2019. In our response to this consultation, CAS observes that:

• The value of the Typical Domestic Consumption Values to both consumers and suppliers is eroded by the use of GB averages. These hide very significant variations in typical annual domestic gas and electricity consumption between the different regions of GB. The Typical Domestic Consumption Values could therefore be made more relevant were they to be reported as a series of averages by electricity distribution network operator region. This would be consistent with how gas and electricity tariffs are priced in GB.

• For properties with wet electric heating systems and/or supplied via multiple electricity meter points, the aggregation of all multi-rate electricity meter types results in a series of Typical Domestic Consumption Values that significantly misrepresents consumers’ total annual consumption and their peak:off-peak consumption split. With the possibility that the revised Typical Domestic Consumption Values will be integrated into the prepayment and default tariff price caps at a later date, there is a need for a discreet set of Typical Domestic Consumption Values and peak:off-peak consumption splits to be produced for a small number of related multi-rate electricity meter sub-profiles.

• In addition to providing a more balanced and more locally representative price cap, these changes would also allow suppliers to provide consumers with better quality information on how their energy use compares with similar consumers, and better quality, more relevant advice on energy efficiency.

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.