In its response, the EIUG would like to emphasise that consumers include non-domestic energy consumers, such as energy intensive industries (EIIs). Too often when energy industry stakeholders, including Ofgem, speak about consumers, they have domestic energy consumers only in mind thereby ignoring non-domestic energy consumers. Issues for domestic and non-domestic energy consumers can be similar, but can also be quite different. It would be useful if Ofgem acknowledges better in its publications that, when it talks about consumers, it means domestic and non-domestic energy consumers.
Key points on the forward work programme:
- The EIUG generally agrees with Ofgem’s forward work programme;
- Key priority for the EIUG is to ensure that all energy intensive industries that should benefit from the Energy Bill Reduction Scheme (EBRS) do benefit from it and that the Energy Bill Discount Scheme (EBDS) is designed and implemented in a way that works for them;
- The EIUG would caution applying any retail market reform of the domestic market to the non-domestic market, as this may reduce competition and increase energy costs.
- The EIUG support the proposal in the work programme to support a secure energy supply for winter 2023/24 and beyond, but would add supporting National Grid in its further development of demand side response (DSR) products for both electricity and gas.