1. Chris Warner Network Code Manager
Proposed Agreement For Identification And Administration Of Unregistered Sites
Chris Warner
Network Code Manager

2. Unregistered Sites An “Unregistered Site” is:
new Meter Point Reference Number in Transporters’ Supply Point Register (SPR)
no User Registration (or prior registration) in SPR
legitimate status where no gas is flowing (usually ‘siteworks’ in process)
illegitimate status where gas is being consumed i.e. potential that gas has been illegally taken whilst in the course of conveyance
no supply contract between supplier and consumer (NB: Ofgem has the view that a Supply Contract is not ‘valid’ if there is no User Registration in SPR)
socialised risk (energy reconciled via RbD)
Shipperless Sites are not within scope of this agreement

3. Transporter Obligations
Transporters Licence Condition 7 obligations
to investigate where it appears gas is taken whilst it is ‘in the course of conveyance’
to use reasonable endeavours to recover the value of the gas taken in such circumstances (Gas Act Sch 2B provides legal ability to do so)
‘ in the course of conveyance’
where a supply contract (or a deemed supply contract) is in place, any point upstream of the ECV
where there is no supply contract (or deemed supply contract) is in place, at any point

4. NGD / BGT Agreement (Pilot) – BGT to Provide Service on behalf of NGD
information from existing Xoserve Unregistered Sites (“Orphaned”) reporting
for ‘shipper activity’ MPRNs, relevant shippers have confirmed ‘no interest’ or not responded to request
undertake investigation (LC7) on behalf of NGD to
establish whether gas is being consumed
establish if a supply contract is in place
BGT to comply with requirements in respect of treatment of vulnerable customers
if gas is being consumed and there is no supply contract in place
use reasonable endeavours (LC7) on behalf of NGD to recover the value of the gas costs (NB: no investigation costs)
notify consumer that it must enter into a supply contract with a supplier
possible future service to undertake disconnection on behalf of NGD where instructed to do so by NGD

5. BGT Service – Treatment of Cost and Revenues
Value of gas costs recovered by BGT on behalf of NGD are returned to NGD
NGD pays BGT for investigation and cost recovery services
BGT charges required to be reasonable and cost reflective
NGD treats revenue recovered and investigation and costs recovery charges in accordance with Licence Condition 7(3) Scheme
Changes made to Licence “Transportation Revenue” to maintain revenue neutrality

6. BGT Service – Status
Ofgem is aware of proposal and following various challenges dialogue has taken place to ensure arrangement is acceptable
NGD and BGT intends to commence pilot as soon as possible
bilateral arrangements to be finalised
operational processes/interfaces to be concluded

7. BGT Service – Next Steps
Costs and revenues to be monitored on an ongoing basis
Pilot likely to commence Q and last 12 months
At this point review to be conducted and decision taken on whether to extend duration of arrangement
Potential success criteria
volume of consequential User registrations
proportion of invoiced charges recovered
extent to which costs recovered meet service charge
residual theft detection

8. BGT Service – Next Steps
Comments?
To National Grid
To Ofgem