Ofgem suggestions on the draft guidance
on social and environmental objectives
Paragraph 1.2 See main letter.
Paragraph 2.4 It is inappropriate for the
Government to invite the Authority to make the Social Action Plan
permanent, since we are already committed to this. Perhaps the
guidance could welcome the Authority's commitment to updating
the plan each year.
Paragraph 2.6 The third bullet point would
seem to fit better in paragraph 2.10 which covers disconnection,
or paragraph 2.15 which covers security of supply.
Paragraph 2.13 The meaning of the last sentence
is unclear, and would be better omitted. If the intention is that
Ofgem should have a detailed role in brokering individual infill
schemes then it is doubtful this would be a sensible or appropriate
use of resources.
Paragraphs 3.4-3.5 The guidance should take
account of the publication of our Environmental Action Plan on
20 August. It would therefore not be appropriate for the guidance
to suggest what should be covered! In fact the areas suggested
in the draft have been included, although as regards the quantification
of environmental consequences the approach which we have found
practical has been to make a commitment to doing this where feasible
in future and to draw attention to where we have done it recentlyfor
example in relation to methane leakage as part of the Transco
initial price control proposals in June 2001. As with the Social
Action Plan, it would be inappropriate for the Government to invite
us to make the Environmental Action Plan permanent, as we are
committed to annual updating.
Paragraph 3.11 You may wish to review the
statements about the Government's targets for electricity supplied
by renewable sources by 2003, in the light of DTI's consultation
on the Renewables Obligation launched on 3 August. The final sentence
of this paragraph encouraging us to assess the impact of NETA
will have been satisfied when we publish our review in the near