BSC Panel July 2013

Report on Progress of Modification Proposals Adam Lattimore 11 July 2013

2 Modifications Overview NewP294, Issue 48 Definition- AssessmentP283, P291, Issue 46, Issue 47 ReportP293 With Authority P272, P286, P292 Authority Determined - Self-Gov Determined -

214/04 P295 ‘Submission and publication of Transparency regulation data via the BMRS’ Talia Addy/Tariq Hakeem 11 July 2013

P295 – Transparency Regulation Tariq Hakeem - National Grid

5 P295 - Issue  Regulation No 543/2013 (Transparency Regulation) has come into force with an implementation date of 4 th January 2015  The regulation sets out a number of data items that Transmission System Operators (TSOs) have to submit for publication on Electricity Market Fundamental Information Platform (EMFIP)  National Grid as TSO will be required to submit data on behalf of primary data owners  P295 proposes that National Grid submits data to Elexon who then submit the data to EMFIP on behalf of GB  Consideration needs to be given to the interaction between outage data published under P295 and that published under P291

6 P295 - Solution  National Grid submits a large amount of data to Elexon to support settlement arrangements - some of this data is published on the BMRS  P295 proposes that the information for publication on EMFIP is submitted to Elexon via the existing National Grid / Elexon data channels for onward submission to EMFIP  BSC parties may well derive value from the publication of some / all of this EMFIP data on BMRS

7 P295 - Benefits  Submission of EMFIP data via Elexon would allow BSC parties to decide how much of the data should also be published on the BMRS, and in what formats etc  Changes to publication and formatting of this data will be under the governance of Elexon and could be amended more easily should BSC parties require it  Submission via Elexon also utilises existing data channel infrastructure

8 P295 – Applicable Objectives  Better meets Applicable BSC Objective (c) – publication of data on BMRS would allow information to be more accessible to BSC Parties; and  Better meets Applicable BSC Objective (e) – P295 would deliver the legally binding regulation more efficiently as the data would use existing National Grid / Elexon data channels

9 Amend the BSC to allow ELEXON to be the GB data provider for all data that the Transmission Company is required to submit to the EMFIP under the Transparency regulation Some or all of this data published on the BMRS P295: Modification Proposal

10 What information is required under the Transparency regulation? What information should be published on the BMRS? What are the obligations on submitting the information? P295: Things to Consider (1 of 2)

11 What changes are required to support the proposed solution? Are there any alternative solutions? What are the benefits against the Applicable BSC Objectives? P295: Things to Consider (2 of 2)

12 Recommend that P295 progresses to an Assessment Procedure Recommend a four month Assessment Procedure Three Workgroup meetings 15WD Impact Assessment & 15WD Assessment Consultation Assessment Report presented to Panel in November Workgroup membership should include: P291 & Issue 47 Workgroup members SSMG members Other relevant experts & interested parties P295: Proposed Progression

13 The Panel is invited to: DETERMINE that Modification Proposal P295 progresses to the Assessment Procedure; AGREE the proposed Assessment Procedure timetable such that an Assessment Report should be completed and submitted to the Panel at its meeting on 14 November 2013; DETERMINE that the P295 Workgroup should be formed from members of the P291 and Issue 47 Workgroups and the Settlement Standing Modification Group, along with any other interested parties; and AGREE the Workgroup’s Terms of Reference. P295: Recommendations

214/05 Request to raise a Modification; ‘Introduction of a ‘Fast Track’ Modification Process following the outcomes of the Code Governance Review (Phase 2) Claire Anthony 11 July 2013

15 Aimed to enable other industry codes to benefit from the CGR Phase 1 outcomes Final outcomes published 27 March 2013, along with a Statutory Licence changes consultation Impact of CGR Phase 2 on BSC Introduction of the new ‘Fast Track’ Self-Governance process The Fast Track process would be used to correct any manifest errors and minor housekeeping changes Code Governance Review Phase 2

16 The Issue: In light of the final publication of the licence conditions, the new Fast Track Self-Governance process needs to be incorporated into the BSC by 31 December 2013 Proposed Solution: The BSC will be amended to introduce the Fast Track Self-Governance Modification Process Modification Proposal

17 Proposer raises Fast Track Self Governance Modification Proposal presented to BSC Panel (Panel unanimously agree) (Panel disagree) Final Fast Track Self-Governance Report Treat either as: published on BSC Website a) Standard ‘Self-Governance’ Modification (15 WDS to object) b) Modification Proposal Fast Track Process

18 Recommend: Report Phase – APPROVE Merits of Proposal are self-evident The Modification Proposal will enable the quick progression and implementation of minor housekeeping changes to the BSC without the need to go through the full Modification process Recommend: Implementation Date 31 December 2013 in line with the changes to Standard Condition C3 of the Electricity Transmission Licence Proposed Progression

19 Modification Proposal better facilitates Applicable BSC Objectives (a) The proposed changes will mean that the BSC is consistent with SLC C3 of the Licence; and (d) The Modification Proposal will enable the progression and implementation of minor housekeeping changes What are the Panel’s views on the Applicable BSC Objectives? Are there any further questions that the Panel would like to ask as part of the Consultation? Applicable BSC Objectives

20 We invite the Panel to RAISE the Modification Proposal in Attachment A SUBMIT the Modification Proposal directly to the Report Phase AGREE a provisional recommendation that the Modification should be made AGREE a provisional Implementation Date of 31 December 2013 in line with the requirement in Standard Condition C3 of the Electricity Transmission Licence AGREE the draft legal text in Attachment B AGREE the draft redlined changes to BSCP40 in Attachment C and AGREE that the Draft Modification Report should be issued for consultation and submitted to the Panel at its meeting on 12 September 2013 Recommendations

214/06 P283 ‘Reinforcing the Commissioning of Metering Equipment Processes’ Claire Anthony 11 July 2013

22 Panel raised P283 on recommendation of PAB Technical Assurance of Metering Expert Group (TAMEG) and ELEXON concerns Certain Metering Equipment usually not within Registrant/MOA control when commissioning required Issues cause incomplete commissioning and records; and incorrect Meter readings (which can lead to significant error) P283: Issue

23 Make Equipment Owner responsible for Commissioning current transformers and voltage transformers Providing relevant records to the Registrant Two tier approach to obligations If BSC Party – obligations would lie with the Equipment Owner (LDSO or Transmission Company) If not a BSC Party – obligations would rest with the Registrant P283: Proposed Solution (1 of 2)

24 Require MOA to confirm status of HH Commissioning to Registrant Metering Equipment commissioned in accordance with CoP4 or Identified defects/omissions in commissioning of Metering Equipment Require Registrant to assess and address identified issues Act to resolve issues that constitute a risk to Settlement Consult relevant participants and agree steps to address issues Could include further commissioning of Metering System P283: Proposed Solution (2 of 2)

25 Unanimous view that P283 would better facilitate: Objective (b), because it would improve the accuracy of metered volumes which would promote effective operation of distribution systems Objective (d), because data entering Settlement would be improved under the P283 arrangements; and Objective (c), because competition would be improved by increased confidence in the Settlement and commissioning processes as a result of the P283 arrangements Panel considered that the main benefits of P283 would be against Objectives (b) and (d), with marginal benefit against (c) P283: Panel’s Initial Views (1 of 2)

26 Unanimous support for Implementation Date 6 November 2014 (November 2014 BSC Release) if an Authority decision is received on or before 6 November 2013; or The next BSC Release at least 12 months from the date the decision is received, if an Authority decision is received after 6 November 2013 Legal text CoP4 drafting P283: Panel’s Initial Views (2 of 2)

27 12 responses to Report Phase Consultation Unanimous support of Modification Applicable BSC Objectives Panel’s initial recommendation to approve P283 Implementation Approach P283: Report Phase Responses (1 of 2)

28 No comments were received on the BSC legal text Several comments received on CoP4 redlining Minor amendments consisting of further clarification and typographical errors, which have been incorporated into the CoP4 redlining No new arguments put forward P283: Report Phase Responses (2 of 2)

29 Panel invited to confirm its views that P283 would better facilitate Applicable BSC Objectives (b), (d) and (c)? P283: Panel’s Final Recommendations

30 We invite the Panel to NOTE the P283 Draft Modification Report and the Report Phase consultation responses CONFIRM the recommendation to the Authority contained in the P283 Draft Modification Report that P283 should be made as it would better facilitate Applicable BSC Objectives (b), (d) and (c) APPROVE an Implementation Date for P283 (if approved) of 6 November 2014 if an Authority decision is received on or before 6 November 2013; or If an Authority decision is received after 6 November 2013, the next BSC Release at least 12 months from the date the decision is received P283: Recommendations (1 of 2)

31 APPROVE the BSC legal text and CoP4 redlining for P283; and APPROVE the P283 Modification Report or INSTRUCT the Modification Secretary to make such changes to the report as the Panel may specify P283: Recommendations (2 of 2)

P291 ‘REMIT Inside Information Reporting Platform for GB Electricity’ David Kemp 11 July /07

33 REMIT requires market participants to publish inside information Regulation does not explicitly set out what should be reported Non-binding ACER guidance provides more detail ACER expressed preference for using central reporting platforms Participants can also use their own websites But this can make it harder for participants to locate all information quickly P291: Background & Issue (1 of 2)

34 BMRS publishes and reports data relating to the BM, Settlement and the market in general Info on BMRS not used in Settlement BMRS website freely available to view by anyone P291 proposed BMRS website as best place for a central REMIT platform for GB electricity market Changes to BMRS reporting require changes to BSC P291: Background & Issue (2 of 2)

35 Central reporting platform will be placed on BMRS website Considered ACER’s best practice example Participants can submit messages via either the ELEXON Portal and/or existing Grid Code submissions Grid Code route could only be used by Grid Code participants and only for outage-related information Participants will be able to choose to use only one route if they wish BSCCo and TC will forward messages received to BMRA for publication Use of the platform would be voluntary P291: Proposed Solution

36 Unanimous: P291 would better facilitate Objectives (c) and (e) Info on public platform means freely accessible to all (c) Ancillary benefits from non-BSC Parties using platform (c) Better facilitate compliance with REMIT (e) Align with spirit of Objective (e) Unanimous recommendation to approve P291 P291: Panel’s Initial Views (1 of 2)

37 Unanimous Panel support for Workgroup’s proposed Implementation Date: 31 December 2014 if approved on or before 31 March 2014 Panel unanimously agreed draft legal text for Report consultation P291: Panel’s Initial Views (2 of 2)

38 Majority view that P291 should be approved Would better facilitate Objectives (c) and (e) – agree with Panel’s views May better facilitate Objective (b) (minority view) Would be detrimental to Objective (d) (minority view) But believes benefits against other Objectives outweighs this impact P291: Report Phase Responses (1 of 4) QuestionYesNoNeutralOther Agree Approve? of 2

39 One respondent has neutral view on P291 Support principle of platform Believe more holistic consideration needed with Transparency reg. (P295) P291 raised to fix specific defect (REMIT platform) Transparency reg. out of scope P291: Report Phase Responses (2 of 4) QuestionYesNoNeutralOther Agree Approve? of 2

40 Several comments received on legal text Some amendments made to improve clarity P291: Report Phase Responses (3 of 4) QuestionYesNoNeutralOther Agree Changes to Code?5002

41 General agreement with Implementation Date Welcome decision to align with Transparency regulation P291: Report Phase Responses (4 of 4) QuestionYesNoNeutralOther Agree Implementation Date?6001

42 Panel invited to confirm its views that P291 would better facilitate Objectives (c) and (e) for the reasons previously given Panel invited to consider the views put forward against Objectives (b) and (d) P291: Panel’s Final Recommendation

43 ELEXON invites the Panel to: NOTE the P291 Draft Modification Report and the Report Phase Consultation responses; CONFIRM the recommendation to the Authority contained in the P291 draft Modification Report that P291 should be made as it would better facilitate Applicable BSC Objectives (c) and (e); [Continues] P291: Recommendations (1 of 2)

44 APPROVE an Implementation Date for P291 (if approved) of: 31 December 2014 if an Authority decision is received on or before 31 March 2014; APPROVE the BSC legal text for P291; and APPROVE the P291 Modification Report or INSTRUCT the Modification Secretary to make such changes to the report as the Panel may specify. P291: Recommendations (2 of 2)

Minutes of Meetings 213 & Actions Arising Adam Richardson 11 July 2013

Chairman’s Report BSC Panel Andrew Pinder 11 July 2013

214/01 ELEXON Report Peter Haigh 11 July 2013

Distribution Report David Lane 11 July 2013

National Grid Update Ian Pashley 11 July 2013

European Update: Ofgem Lisa Charlesworth 11 July 2013

214/01a Report from the ISG 11 July 2013

214/01b Report from the SVG 11 July 2013

214/01c Report from the PAB 11 July 2013

214/01d Report from the TDC 11 July 2013

214/01e Report from the JESG 11 July 2013

214/01f Report from the PSRG 11 July 2013

214/02 Trading Operations Report 11 July 2013

214/03 Change Report 11 July 2013

214/08 Coordination body for the Application of the European Network Codes to the GB framework Ian Pashley 11 July 2013

214/09 Proposed changes to the ISG, SVG and PAB Terms of Reference Adam Richardson 11 July 2013

61 Minor identical changes proposed to ISG and SVG Terms of Reference Correction of typos, style improvements and minor clarifications Minor changes proposed to PAB Terms of Reference To include timescales for papers/minutes No changes proposed to TDC Terms of Reference Proposed changes

62 APPROVE the changes to the ISG, SVG and PAB Terms of Reference with immediate effect Recommendations

The Installation and Commissioning of Metering Systems Elizabeth Montgomerie 11 July 2013

64 TAA / BSC Auditor Annual Report Action to investigate approach Progress Input from: PAB TAA Metering Experts Background

65 Responsibilities clear & enforceable Incentives e.g. Liquidated Damages Report and monitor Centralised body for commissioning records Other outputs from the PAF Cost / benefit analysis Market to industry ‘Problem pots’ Forward looking process fixes vs historical non-compliance fixes Consultation with the PAB

66 Number of work-streams 1.Guidance & Education for Industry Best Practice Impact - £’s & Settlement Responsibilities (P283) Accountabilities 2.New mechanisms 3.Incentives What can we do under the BSC? What do be done outside of the BSC? What is already there? 4.Performance Assurance Framework Manage existing non-compliances and root causes PAB feedback through the monthly report Approach

67 We invite the Panel to: NOTE the verbal update on an approach to tackle the problems related to the commissioning of Metering Systems. Recommendations

Update on the Procurement and Implementation of the TAA Contract Elizabeth Montgomerie 11 July 2013

69 Go Live - 1 April earlier this year. SLAs / Feedback Final Acceptance & Project closure Excellent team work Communicating to our customers Procurement update

70 We invite the Panel to: NOTE the verbal update on the implementation of the TAA contract. Recommendations

214/10 Moving to ‘User Pays’ billing for Data Transfer costs and development of the ELEXON Portal to deliver DTS Flows Neil Tingay 11 July 2013

72 On 9 May 2013, ELEXON took a paper to the Panel (reference 212a/07 with attachments 212a/07a and 212a/07b) which focused on two areas: Firstly how we can use the ELEXON Portal to send Supplier Volume Allocation Agent (SVAA) Flows to industry; and Secondly how we could change the current charging methodology so that BSC Parties are charged for Data Transfer Service (DTS) costs on a ‘user pays’ basis. During the last 2 months ELEXON has had the opportunity to engage with industry, to further clarify our requirements and to gather indicative costs. 214/10 - Background

73 ELEXON have sought feedback through a number of channels including the following; Operational Support Managers (OSMs) Newscast Publication Panel Sub-Committees – ISG, SVG and PAB DTS User Group In conclusion ELEXON consider that the debate has been welcomed by respondents, the response has been very much of a ‘wait and see’ what the exact impact and solution is before committing to a position. ELEXON would expect that if a Modification was raised then the Modification Group would drive this forward and by facilitating further industry debate, all parties would have the opportunity to feed into these discussions. 214/10 – Industry Feedback

74 ELEXON have held a number of meetings with the DTS Service Controller (Electralink) in order to discuss the impact of the use of the ELEXON Portal rather than the DTN as the delivery mechanism for SVAA DTS flows. The DTS Service Controller has indicated that due to the fixed price contract they have with their Service Provider that any revenue lost would be recouped through an increase in charges incurred by Suppliers. 214/10 – DTS Impact

214/10 – Development and Support Costs The development required to the ELEXON Portal and Data Marshalling software (which routes DTS Flows to and from SVAA) is estimated to be in the region of £160k, with an increase in support charges of £45k per annum. The FSS development work required to support the ‘user pays’ charges is estimated to be approximately £25k. Therefore high level total development costs for these changes will be £185k and support costs will increase by £45k per annum.

214/10 – Conclusion In conclusion ELEXON consider that the engagement with industry over the last 2 months has provided useful insight into the thoughts and concerns which surround these two areas, however as these discussions have focused on the principle of these changes rather than the direct impact they would have, it has not been possible to come to a final conclusion. ELEXON recommend that, subject to the internal approval of a business case, the best course of action would be to continue the debate through a Modification being raised. It is anticipated that this Modification would seek to adopt a ‘user pays’ charge for DTS costs on the basis that a separate facility is provided for distributing this data (i.e. the ELEXON Portal solution noted above). This change would provide the opportunity to reduce overall SVA costs associated with DTS charges incurred by BSCCo. ELEXON believes that this Modification could be raised by the Panel on the grounds of efficiency.

77 We invite the Panel to; NOTE the feedback provided to ELEXON; NOTE indicative costs provided to ELEXON; and NOTE that ELEXON may recommend the raising of a Modification during the Panel meeting in August 2013 to support the introduction of a ‘user pays’ charge for DTS costs. 214/10 - Recommendations

Report on Issue 47: GB Implementation of the European Transparency Regulation David Kemp 11 July 2013

Any Other Business

Next Meeting: 8 August 2013