For the past two months Ofgem has had an open call for input on the future of distributed flexibility. This has made us think long and hard about what flexibility means.
There are a lot of documents that discuss flexibility at a conceptual level. But Ofgem’s call forces us to think more deeply about what this means at an operational level. Or in other words, what this looks like, in practice, for customers.
This stimulated many discussions with fabulous colleagues at Regen. And has led to us drafting an open letter to Ofgem. Our letter draws attention to the customer-facing side of flexibility.
It makes four key recommendations:
- Ofgem should embed justice and equity metrics into the design and evaluation of flexibility scenarios and mandate retailers to report on how flexibility payments are distributed according to key socio-demographic indicators.
- Ofgem must address the risk of a digital divide. This includes (a) supporting greater levels of public engagement, (b) understanding the barriers to engaging with digital technologies, (c) supporting the development of solutions to overcome these barriers, (d) building diversity into accountability of energy data governance and decision making, and (e) putting processes in place to recognise, quantify and evaluate the impact of biases inherent in data and its use.
- Ofgem should undertake wider public engagement on customer energy resources and flexibility. This includes providing opportunities for public deliberation and input into policy development.
- Ofgem must create an innovation culture within the sector. This includes (a) supporting bi-directional learning by embedding research within projects and portfolios, (b) reviewing how and for whom innovation works, (c) ensuring projects share insights that support wider learning, and (d) redefining what failure means.