Citizens Advice published its application to intervene in the Competition and Markets Authority (CMA) appeal concerning the RIIO-ED2 Energy Licence Modification on 25 April 2023. The charity said it wished to intervene in order to oppose the appeal, acting under its statutory role to represent domestic and small business energy consumers in Great Britain1.
The application states that allowing the appeal would grant Northern Powergrid (NPg) significant additional revenue, funded by consumers, without any related improvement in service or investment1. Citizens Advice said NPg had not offered any argument or evidence for why the appeal is in the best interest of its customers or consumers more generally, and that it had been unable to find any such arguments itself1.
"Citizens Advice wishes to intervene, to oppose this appeal"
On the question of funding, Citizens Advice said NPg claims to be underfunded but has not provided evidence that this will occur in reality, preferring to compare allowances with a notional figure it has previously raised concerns over1. It said NPg has not demonstrated that it will receive allowances below what it expects to spend, and that comparing against NPg's own business plan suggests NPg would be over-funded if its preferred allocation method were followed1. The charity concluded there does not appear to be any credible risk that NPg will be underfunded, and that allowing the appeal would lead to substantial windfall gains for NPg1.
Citizens Advice placed the appeal in the context of what it described as high returns enjoyed by UK regulated networks companies through regulatory settlements that have proved too generous1. It said any unjustified returns arising from RIIO-2 add unfair cost to consumers' bills at a time of an energy and cost of living crisis, and that such returns will erode the credibility of the regulatory regime and damage customer trust1. It added that a stable regulatory regime is important for consumers, particularly with the increase in investment required for net zero1.
Why it matters for households
Network charges are recovered through energy bills, so the outcome of the appeal bears on what households pay for the wires and cables that deliver electricity, separate from what they pay for the energy itself. Citizens Advice's central claim is that additional revenue for NPg would be funded by consumers without a corresponding improvement in service or investment1. Its wider argument is that settlements it considers too generous to network companies feed through to bills, and that repeated windfall gains could weaken confidence in the regulatory system that sets those bills1. The application was made in the charity's capacity as the statutory representative of domestic and small business energy consumers in Great Britain, a role described in its energy consumer bodies guidance1.
What happens next
The application is a request for permission to intervene in the CMA appeal; the sources do not report a date for the CMA's decision on that request, nor a timetable for the appeal itself. The full application runs to 430 KB and is published by Citizens Advice1. No outcome of the appeal has been reported.