ClientEarth’s submission to The House of Lords Industry and Regulators Committee’s inquiry into Ofgem and net zero

ClientEarth argues that Ofgem's current statutory objectives are outdated and prioritize competition over decarbonisation, hindering long-term climate investments. The submission proposes narrowing Ofgem's principal objective to focus on security of supply and greenhouse gas reduction, introducing sector-specific carbon budgets, and requiring the Department for Business, Energy and Industrial Strategy (BEIS) to issue periodic Strategy and Policy Statements. Additionally, ClientEarth highlights a failure to regulate and verify non-carbon dioxide emissions, specifically methane and sulphur hexafluoride (SF6), and advocates for a consumption-based emissions accounting approach to include extraterritorial emissions from imported energy.

• Ofgem's current regulatory framework is designed for competition, which makes it difficult for the regulator to prioritize long-term decarbonisation projects that may increase short-term costs for consumers.
• ClientEarth proposes narrowing the principal objective of the Electricity Act 1989 and Gas Act 1986 to focus exclusively on security of supply and the reduction of targeted greenhouse gas (TGHG) emissions, ensuring this objective takes priority over others.
• There is a lack of strategic leadership and clarity regarding the division of responsibility between Ofgem and BEIS; ClientEarth recommends a statutory duty for BEIS to publish a Strategy and Policy Statement every three years.
• The UK lacks rigorous verification for non-carbon dioxide greenhouse gases, particularly methane and sulphur hexafluoride (SF6), relying instead on self-reporting by market participants which often leads to underestimation.
• Ofgem has allegedly failed to comply with BEIS's system modelling guidance for greenhouse gas emissions, specifically regarding the Targeted Charging Review (TCR), where BEIS was not involved in the analysis.
• ClientEarth advocates for a consumption-based emissions accounting approach to prevent the UK from increasing extraterritorial emissions through imports of fossil gas, gas-based hydrogen, biomass, and electricity.

APA

ClientEarth (2021). ClientEarth’s submission to The House of Lords Industry and Regulators Committee’s inquiry into Ofgem and net zero. https://www.clientearth.org/media/zihj42ng/clientearth-submission-to-uk-hol-inquiry-into-ofgem-and-net-zero.pdf

Chicago

ClientEarth. ClientEarth’s submission to The House of Lords Industry and Regulators Committee’s inquiry into Ofgem and net zero. 2021. https://www.clientearth.org/media/zihj42ng/clientearth-submission-to-uk-hol-inquiry-into-ofgem-and-net-zero.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth’s submission to The House of Lords Industry and Regulators Committee’s inquiry into Ofgem and net zero |date=1 August 2021 |url=https://www.clientearth.org/media/zihj42ng/clientearth-submission-to-uk-hol-inquiry-into-ofgem-and-net-zero.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021clientearths, author = {{ClientEarth}}, title = {{ClientEarth’s submission to The House of Lords Industry and Regulators Committee’s inquiry into Ofgem and net zero}}, publisher = {ClientEarth}, year = {2021}, month = aug, url = {https://www.clientearth.org/media/zihj42ng/clientearth-submission-to-uk-hol-inquiry-into-ofgem-and-net-zero.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }