We asked
We asked for views from stakeholders on our draft guidance about how AI should be used in Great Britain’s energy sector.
Our consultation questions asked whether the:
- existing regulatory framework is adequate to govern the use of AI
- good practice guidance covering governance, risk approach and competencies is sufficient for the ethical adoption of AI
You said
We received responses from:
- Cadent Gas
- Cambridge Consultants
- Ceimia
- Centre for Net Zero
- Centrica
- Citizens Advice
- Crackle Energy
- DNV
- EDF Energy
- Electricity North West
- Energy Systems Catapult
- Energy UK
- E.ON UK
- Flexitricity
- Health and Safety Executive (HSE)
- IBM
- Icebreaker One
- Kraken Technologies
- Lane Clark & Peacock
- Microsoft UK
- National Grid
- Nemo Link
- Northern Gas Networks
- Northern Powergrid
- Northumbria University
- Octopus Energy
- Ömer
- OVO Energy
- Scottish Power
- Smart Energy Code (SEC) Panel Privacy Sub Committee
- Siemens Energy
- SGN (formerly Scotia Gas Networks)
- SP Energy Networks
- SSE plc
- SSE Energy Services
- Scottish and Southern Electricity Networks (SSEN Transmission)
- UK Power Networks
- University of Bristol
- University of Oxford
- University of York
- Urban Chain
- Utility Customer Service Management (UCSM)
There is broad support for the guidance and its outcomes-focused approach. A minority of stakeholders provided critical constructive feedback. Some expressed views that less prescription was needed. Others said more specific responsibilities for regulated persons were required.
Specific issues identified by these stakeholders included:
- The AI definition is vague and can be interpreted to be inclusive of things which are not AI.
- The positioning, clarity of scope and status of the guidance is uncertain and clashed with the intended outcomes focused and proportionate approach.
- The suitability of the regulatory framework to deal with AI challenges.
- Areas not explicitly covered by the guidance, for example, the responsibilities of third parties and non-licensees.
We did
We have fully addressed these issues by making appropriate revisions to the guidance. This ensures clarity around its purpose, scope and effect.
We will keep the existing regulatory framework and this guidance under review. This will ensure our approach continues to meet the needs of regulating AI effectively in the energy sector.
See our Ethical AI use in the energy sector guidance for details on good practice covering governance, risk approach and competencies for the ethical use of AI.
Read our policy page on the Ofgem website which outlines the steps we have taken in developing our regulatory approach to AI.
We asked
We asked for views and feedback to help us update the Consumer Vulnerability Strategy.
You said
We received 67 responses, which broadly supported our proposed themes and outcomes.
There were some suggestions for more specificity, clarity and scope of certain outcomes. For example, some respondents said we should include financial vulnerability in the definition of vulnerability. However, most agreed that other work should be prioritised over updating the definition.
The aims of our proposed annual supplier presentations were also generally welcomed. However, there were concerns about the potential regulatory burden and duplication of existing work. Some suggested other ways to meet our objectives in increasing transparency and accountability.
We also received responses which offered support or suggestions on individual workplans such as the Priority Services Register, debt and affordability, consumer confidence, and innovation.
We’ve published the responses we received, apart from those that were marked as confidential.
We did
After considering the responses, we:
- made some minor wording changes to the outcomes to add clarity;
- set out reasoning for retaining the current vulnerability definition;
- adapted our proposal to engage with suppliers annually.
See our response summary (PDF 206 KB) for more details on what we have changed and why.
We asked
We asked for views about our draft guidance for the National Energy System Operator (NESO) to produce future energy pathways. Our main questions were whether the guidance accurately reflected the decisions we had made on the changes to this work.
We were looking for responses from people and organisations who are currently using or will be using the Future Energy Pathways.
You said
We received responses from:
- Energy & Utilities Alliance (EUA)
- Northern Gas Network
- Octopus Energy Group
- Intergen
- UKPN
- Energy UK
- Cadent Gas
- The Crown Estate
- ENWL
- Hydrogen UK
- SSE
- ESO
- EDF Energy
- WW Utilities
- ESB Generation and Trading
- National Gas Transmission (NGT)
- Northern Powergrid
- SGN
- SP Energy Networks (SPEN)
- RWE
The majority of responses agreed that we had accurately reflected our decision in the guidance. Most responses asked for more clarity in certain areas, particularly around:
- how the pathways will interact with the other NESO planning roles
- whether regional pathways were still needed in this process
- how distribution level, and gas data, will be incorporated in the future
Where we were given permission, we’ve published the responses we received.
We did
We have decided to amend the guidance in line with positions laid out in the responses, mainly a number of minor changes to add clarity. We have made three more substantial changes to:
- drop the requirement for the Future Energy Pathways to produce regional pathways, which will now be done as part of the regional planning work that NESO is undertaking
- require that NESO explain in its Future Energy Pathways publication exactly how the future energy pathways work interacts with its other planning responsibilities
- require NESO to explore with stakeholders how, and over what timescale, this work can include more distribution level and gas network information
See our decision document (PDF, 181.9 KB) and tracked changes (PDF, 197.7 KB) for more details on what we have changed in the final guidance, and why.
Read our notice of direction for the Future Energy Pathways guidance (PDF, 86.1 KB).
View the latest version of the Future Energy Pathways guidance on the Ofgem website.