We welcome the opportunity to respond to this consultation. Our non-confidential response represents the views of the Retail Energy Code Company Ltd (RECCo), and is based on our role as operator of the Retail Energy Code (REC), which includes governance of the Central Switching Service (CSS), operated by the DCC.
Summary of key points:
• RECCo supports the holistic development of new arrangements for the governance and funding of the DCC, building upon the proposals under Option B;
• Option A is unlikely to address the misalignment of interests inherent in the current model;
• notwithstanding the current pressures upon Ofgem, the decision on which model to progress and over what timescale must be taken on its merits, and cannot appropriately be influenced by Ofgem resource constraints or competing priorities;
• there is opportunity for incremental improvement ahead of 2025, increasing certainty reducing risk, both for the transition and to potential service providers; and,
• the Central Switching Service is a distinct business and should appropriately be unbundled from the smart communications business, allowing each to be governed and to develop as appropriate, rather than compromised by the interests of the unrelated business.
Our response to the consultation questions is appended to this letter. We appreciate the reasonable time period that you allowed to respond to this consultation and would be happy to discuss any of the points raised in further detail whether technical or regulatory.e Company Ltd (RECCo), and is based on our role as operator of the Retail Energy Code (REC).
Read our response in full here.