UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

UNC Mod 395 – Retrospective Invoice Limitation Distribution Workgroup 25 August 2011 UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Overview Objectives of Mod 395 Electricity Arrangements Sites impacted – some examples Other areas of interaction USRVs Must Reads Next steps UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Objective of Mod 395 Reduce exposure of Shippers to retrospective invoices going back up to 5 years by Reducing the invoicing window to a 2 – 3 year model – note on average 30 month window Applied to all invoices May also Encourage more timely reading of some meters Encourage proactive management of must read process UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

What are the electricity arrangements? Final Settlement Run at 14 months Parties able to raise a request to disputes committee prior to 20 months Dispute Final Run occurs at 28 months If a new issue arises in final settlement run parties able to raise further dispute within 1 month UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Impact of 395 – annual read site with annual readings Meter reading submitted Meter reading submitted Meter reading submitted Meter reading submitted Meter reading submitted Meter reading submitted Rec. period closed Rec. period closed Rec. period closed Rec. period closed Mod 152V – window moved to 1 April 2010 – no impact on reconciliation Mod 395 – window moved to 1 April 2012 – no impact on reconciliation UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Impact of 395 – annual read site with bi-annual readings Meter reading submitted Meter reading submitted Meter reading submitted Rec. period closed Mod 152V – window moved to 1 April 2010 – no impact on reconciliation Mod 395 – window moved to 1 April 2012 – impact on reconciliation UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

USRV Impacts 264 USRVs impacted by Mod 395 as of July 2011 USRVs at greater than 2 years reducing at circa 30/month UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Must read impacts Only impacts on must reads in April – July period Assumes majority of most must reads actioned within 3 months May encourage Shippers to proactively engage on must reads in the Jan-March period? Need to quantify impacts: Number of must reads actioned on monthly basis for previous 24 months Xoserve to provide? UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

Next steps Other issues to be considered: What settlement period should the industry be aiming for? Are there any impacts on credit/securitisation issues – can these be quantified? Any other issues? Aiming for 1 April 2012 implementation date What notice from Ofgem is required – xoserve to provide UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.

UNC Mod 395 - Retrospective Invoice Limitation © 24 November 2009 EDF Energy plc. All rights Reserved.