It investigated whether ”Smart meters don’t solve climate change on their own. But with the smarter, more efficient energy grid they help to create, they’re a start” among other claims. Did the ads gave a misleading impression of the environmental benefits of smart meters? No, said the ASA. The complains were not upheld.

In July, the ASA came down firmly on the side of Friends of the Earth, when the pressure group claimed on its website that “Fracking is incompatible with tackling climate change” and “Fracking risks contaminating groundwater”. In a lengthy examination of the issue, the ASA considered the views of the Climate Change Committee, and saw that the CCC thought the government had not met tests for making fracking climate-compliant. The ASA also decided that it was not misleading to claim there was a risk that fracking could contaminate groundwater and that groundwater could end up being used as drinking water. It had examined experience in the USA and how that differed from the UK situation.

In contrast, this week the ASA stopped supplier Outfox the Market from claiming it was the cheapest supplier. The ASA highlighted the shortcomings of price comparison websites, saying, “… energy providers who did not subscribe to or might chose not to be included in price comparison websites and, therefore, the evidence provided might not represent a full comparison of all energy providers in the UK… we considered that listings from comparison sites would be unlikely to constitute robust, comparative and representative data relevant to all consumers, as required to support absolute, whole market claims.”

There are more – see links below.

The ASA is not the energy regulator. But I am starting to wish it was. Energy company price claims,whether consumers really understand price comparison sites’ limitations, whether fracking could cause contamination – all these are real, important issues in the sector. They are not being addressed by the energy regulator. You have to wonder, in the debate over the future of regulation in utilities, whether the net should be spread a little wider. The regulator tends to dismiss suggestions that consumer regulation could be effective in a sector as ‘difficult’ as energy. The ASA seems to be answering that question.

Meanwhile, Ofgem and the CMA might pick up a hint: what are the limitations of price comparison websites?

Further reading

Outfox the Market told to moderate advertising claims – comparison sites ‘not proof’

Advertising watchdog dismisses challenge over Friends of the Earth claims on fracking’s climate and water fears

Not a watchdog

Public Accounts Committee: sector regulators are failing consumers

Is it time to re-examine the regulatory model?

BT Solar Ltd censured over misleading ad

E.On has to withdraw ’70-year history’ advert

You may have noticed that the debate over how to replace carbon emissions has reached your kitchen. Our current reliance on gas for domestic heating is damaging the climate and it has to be replaced. That may be with a different gas such as hydrogen in your pipes instead of natural gas. It may be as part of a heat network with hot water pushed from an external source to you and your neighbours. You may have heat via a highly-efficient electrical heat pump – in your own property or serving several.
You can be an enthusiast or a sceptic for any of these options. But you are unlikely to get a free choice – and your choice will at least partly be determined by your neighbours.
Why is that? It’s because all these options require you to be on a network and some networks are more future-proof than others.
There has been a lot of discussion about the need to upgrade the electricity grid to manage charging for electric vehicles, but rolling out heat pumps also starts to test the grid capacity (although both are also useful in contributing flexibility). So the heat pump rollout will increase the pressure to upgrade the electricity network.
Nevertheless, for most property owners installing a heat pump is your own decision.
What about the hydrogen option? On a domestic scale this has to be undertaken for a group of properties that are all on the same section of the gas network, that can be sectioned off and the hydrogen can be injected. This is all or nothing: all the gas customers will switch to hydrogen.
This is where it is important to know what your neighbours think. If everyone is an enthusiast, that works. What if they are not?
Some may object to the change and want to retain the gas. Others would no doubt rather take a different route, like a heat pump (full disclosure, I had a heat pump installed this year). The latter decision can be taken independently of your neighbours. The former cannot.
In among its Green Day announcements the government promised to extend its Boiler Upgrade scheme to 2028, and it still has a target to install 600,000 heat pumps per year.
Where will they be? This has important implications.
A rash of heat pumps in one area (as happened with PV, when neighbours followed each other to install it) will make the gas grid look less favourable for hydrogen conversion. So how many hydrogen refuseniks does it take to make it uneconomic to convert a section of the gas network to hydrogen? A quarter? A half? What if you want to retain your gas and there are relatively few users on your branch of the gas network – who pays to maintain that connection – and the gas in the pipes?
There are many other issues to consider. Heat pump users may still use gas for cooking, for example. Domestic hydrogen conversion looks most attractive near industrial clusters that will be using hydrogen for other purposes. But what if they are also the areas where heat pumps are most popular? Will area-based decisions be robust over years, if individuals start installing heat pumps?
What about parts of the network that also serve the gas engines that provide power at peak times?
Energy networks are opening up their data so third parties can use it and it is time to begin feeding information to customers about what their options are likely to be. At this point, interested parties should be able to find out about the layout of the gas and electricity networks and where the junctions are, so they can take a view over their local branch and its likely future. That should extend to consumers (via third parties that can be trusted and maintain security against external threats, such as local authorities or the network themselves).
Electricity bills include a letter code that comes into play if it is necessary to impose rolling power cuts. In that event you can see when you (or your vulnerable relatives) will be off supply. That’s information that will be needed for the short term, in a power emergency. Something similar will eventually be needed so people can take informed decisions if and when they are making decisions about heat. That’s information that is needed for the long term, in a climate emergency.

Come clean
Of course, what we really need to help sort out this mess is a government steer on the future.
In some areas homeowners will start to lose choice on heating options. Using hydrogen for domestic supply is likely to start near hydrogen industrial clusters. Government is to be applauded for investigating and promoting heat networks, but they will not work everywhere.
For some areas heart pumps are likely to be almost the only option.
Where are those areas? Knowing that could allow other decisions to be made. In the case of electric heating there are so many things that could be done: a new variable to add to the decision-making process on reinforcing the electricity grid in those areas; pilot projects on optimising electric mobility and heating; training for local installers; subsidies for people who need to change their boilers; holistic thinking about areas where most properties are rented; street by street insulation upgrades for the fuel poor; incentives for ‘final users’ to change over where it would allow a gas network spur to be decommissioned.
The key point is: which are these areas? Not all are known at this stage but some clearly are. Making that public would allow everyone – manufacturers, installers, network operators, local authorities, landlords and consumers – to start making better, more future-proof decisions.

Download the full interview Bulb interview 2016

Large fossil plants are not very flexible
Here fossil plants are often brought into play. But here is the point: despite their reputation, large fossil plants are not very flexible. They have to be ‘warmed’ and running in neutral so they are ready to kick in at the peak. That takes up to six hours. What is more, once such a plant shuts down, it has to be down for at least six hours before it can start up again and go through the warming process.
That costs the consumer. If NGESO wants to call on one of these plant it will have to pay it for all the time required to warm up and stand by – even if, in the end, it is not required. If the fossil plant was operating earlier in the day and it might be required later, NGESO will have to pay the plant to stay warm between the two periods, so it does not get caught in the necessary down time.
(It should not be forgotten that as well as the power and warming cost, warming up and operating these units involves carbon emissions. The cost of permits may be covered by the price, but the emissions are real.)
Other options are faster. Small gas engines can warm and operate much more quickly; if the wind is blowing, wind turbines can generate more or less at very short notice; hydro can also respond quickly. But the SO is performing a complex balancing act and other system requirements may mean these are not suitable substitutes for the large fossil plants.
What this shows is that to reduce costs the demand side is absolutely vital. Shifting heating, cooling or vehicle charging by half an hour, or an hour, is feasible and with enough people taking part in such schemes should be entirely voluntary.
A trial now under way with Octopus Energy customers is doing exactly that. Using just a million customers and asking them to turn down for two hours it is hoped the trial will see response of 150MW – about half a large fossil station. Twice as many volunteers would replace one fossil power station – and as we have seen above, that means savings for far more than that two-hour window.
Fossil plant has had a reputation for flexibility for too long. Its time customers were able to show just how efficiently the system can be managed.

More pressure needed to address higher voltage
Whatever the limitations of the ED2 proposals, distribution networks have the benefit that alternatives to SF6 are being developed and are becoming more commonly used. But at higher voltage, satisfactory replacements are more difficult to find – and the high-voltage network is expanding rapidly, both on and offshore. What is more, the regulators will have fewer opportunities to put pressure on new high-voltage network operators.
Although the problem is acknowledged in a new draft of the National Policy Statement (NPS) on energy, where SF6 is singled out as “an extraordinarily potent greenhouse gas”, it leaves large loopholes that could see the gas in use for decades.
In the draft NPS BEIS says “The climate-warming potential of SF6 is such that applicants should, as a rule, avoid the use of SF6 in new developments.” But it says, “Where no proven SF6-free alternative is commercially available… the continued use of SF6 is acceptable.”
Project developers are expected to consider “at the design stage” whether the development could be “reconceived” without SF6 and explain the reasons and costs if they believe it cannot. But the Secretary of State can approve SF6 applications if there is no proven commercially available alternative, if a “bespoke SF6-free alternative would be grossly disproportionate in terms of cost” and “provided that emissions monitoring and control measures compliant with the F-gas Regulation and/or its successors are in place”.
Under the price review process, incumbent transmission networks will have a new hurdle to cross every five years as incumbent and regulator settle on a price determination. As Sustainability First’s call regarding distribution networks shows, the review offers an opportunity to reset the baseline in response to new options on SF6.
But offshore connections are given a licence lasting two decades or more and – if the regulator expands onshore network competition as planned – an increasing number of onshore high-voltage links will operate under similar long licences.
As the number of such links increases, it is more important than ever that the licence requires SF6 management and reduction over the long term – and not an approach that was ‘best available technology’ at a design stage 20 years ago.

Further reading
The worst greenhouse gas: why the electricity industry has to grapple with SF6
Greater Gabbard OFTO ‘could not have forseen’ seal failure that released SF6