RBD NOTIFICATION PROCESS

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Presentation transcript:

RBD NOTIFICATION PROCESS Stefan Leedham Mod Review Group 131 Meeting 30 May 2007

WORK TO DATE Discussions in Review Group and Offtake Arrangements Workstream on “pre-643” notification Presentation from WWU regarding basic meter error information provision Decision by Offtake Arrangements Committee that they were best placed to discuss meter error issues and receive updates Still unclear at what point Shippers can become involved in the pre-notification process Potential ways forward? Shippers involved in pre-MER discussions Shippers involved post MER discussions

SHIPPER INVOLVEMENT PRE-MER Advantages Improves transparency Potential for dispute avoidance Reduces time required for Shipper analysis post-MER Disadvantages No clear trigger Reluctance over double auditing Concern over accuracy of information Content with the “black box”?

SHIPPER INVOLVEMENT POST-MER Advantages Clear trigger Accurate information Maintains status quo Avoids duplicate auditing Disadvantages No transparency of process Increases time for Shipper analysis/verification Potential requirement to delay invoice Missed opportunities?

Or WAY FORWARD Publication of initial information as suggested by NGG Undertaking by Transporters to provide information to impacted Shippers when available Creation of a OAC Sub-committee to discuss particular meter errors Created on request from an impacted Transporter or two or more directly impacted Shippers The OAC Sub-committee can decide (by majority) when the next meeting will be held, the issues to be discussed and what information should be shared and when Or Submission of a Final MER to the upstream Transporter will trigger the ability to create an OAC Sub-committee with impacted Transporters and directly impacted Shippers invited to attend

ROLE OF OAC SUB-COMITTEE On submission of a FINAL MER the next scheduled OAC that is at least 10 business days away will discuss the MER An invitation to Users will be issued at least 10 business days prior to the OAC explicitly stating the size and value of the proposed reconciliation At the OAC Committee an OAC Sub-committee will be created on request from either a Transporter or two directly impacted Shippers Prior to issuing an invitation to Users the Transporters will make all of the information relevant to the error available on a public website An invitation to all impacted Shippers will be issued to the OAC Sub-committee with at least 10 business days notice informing them where the information can be found

ROLE OF OAC SUB-COMMITTEE CONT. The OAC Sub-committee will be able to discuss the error and request additional information to be made available At the end of the meeting the OAC Sub-committee will be able to decide whether the error is ready to be progressed or whether further information and/or time is required and the date of the next meeting. This will be decided by simple clear majority of Shippers This process will be limited so that the time between calling the OAC Sub-committee and the final meeting is not greater than the time elapsed between identifying the meter error and submitting the FINAL MER If at the final meeting of the OAC Sub-committee issues remain with the proposed reconciliation then this will be treated as a dispute under Section A of the UNC

ISSUES TO BE ADDRESSED Is engagement pre or post MER preferred? Should there be any limits placed on the information that the OAC sub-committee can request in relation to the error? Should there be a time limit between requesting the information and Transporters being required to produce it? Do Shippers need to be able to identify which other Shippers are also directly impacted? Impact of Mod Review Group 126? Voting rights of Shippers – by licence or by company? Any additional issues?

THANK YOU