1. Code Administrator Working Group - BSC Chris Rowell (020 7380 4337) 28 August 2008

2. BSC Overview Balancing and Settlement Code (BSC) 1 document - 806 pages Modification Procedures (BSC, F) 225 Modification Proposals Modification Group > Panel > Authority Code Subsidiary Documents (CSDs) 140 documents ~ 7000 pages Change Management (BSCP 40) 795 Change Proposals Panel Committee

3. 1. Effective Consultation Consult during Definition, Assessment & Report (typically 2 weeks) Send to ~360 self subscribed recipients (plus identified groups) Commitment of BSC Agents to Implementation Dates Limited engagement – typical number of responses 10 Limited information on BSC Party business impacts (e.g. costs & savings) Difficulties couching arguments in terms of Applicable BSC Objectives promote inclusive, accessible and effective consultation

4. 2. Transparent Processes be governed by rules and processes that are transparent and easily understood Roles defined in Section F of BSC (Web) published timetable with public meetings & documents Easy to launch a proposal Bodies meet as independent experts Named contacts for all changes Information “comprehensive” Risk that with 3 “gates” - some arguments are held back Misalignment of objectives – Mods Groups & Panel v Authority

5. 3. Administration be administered in an independent and objective fashion Struggle to produce papers “by committee” “Critical friend” role v independence ELEXON required to provide facilities, services & secretariat ELEXON additionally provide chairman, lead analyst, change drafting (+ operational experts) ELEXON primary source of analysis – reducing Party burden, delivering a consistent product

6. 4. Quality Analysis provide rigorous and high quality analysis of the case for an against proposed changes Limited number of responses Limited information on business impacts (e.g. costs & savings) Difficulties couching arguments in terms of Applicable BSC Objectives & their limited coverage Mods Groups work to Panel ToRs Drive towards qualitative, if not quantative, arguments Increasing sophistication in framing arguments around Applicable BSC Objectives

7. 5. Cost Effective be cost effective Substantial volumes of published materials – difficult to assimilate Use of ELEXON offices Try to contain “meeting miles” – joint meetings Use of ELEXON staff v consultants Batch changes into Releases – certainty over Implementation Dates Costs published & challenged

8. 6. Flexible One size – including for “Housekeeping Changes” Once launched cannot be terminated Aided by commitment of Proposer & dependent on Modification Group members Urgent Process Timetable can (but is rarely) varied contain rules and processes that are sufficiently flexible to circumstances that they will always allow for efficient change management

9. 7. Proportionate be delivered in a manner that results in a proportionate regulatory burden No rejections due to lack of adequate analysis Some Modifications largely self evident – require controls but not Authority decisions Late identified analysis gaps can only be addressed by rejection (rather than reassessment)