1. CSEPs Reconciliation “Read Window” proposal

2. 2 Background  I&C CSEPs (supply point AQ >73,200) are subject to reconciliation  IGTs are obliged to provide reconciliation data to xoserve within 30 days of receiving a read  IGT data should include start and end read dates, and actual volume  xoserve will use the actual volume to create a reconciliation  As the rec is for an LMN, the dates need to match xoserve’s LMN dates  IGTs have highlighted the fact that read dates do not always match LMN dates held by xoserve  This results in rejections and unprocessed reconciliation

3. 3 When will there be a mismatch?  There will be a mismatch wherever the dates for the reconciliation do not fall entirely within the LMN dates held by xoserve  The issue is assumed to occur at installation and transfer of ownership

4. 4 Why is there is a mismatch?  Weekly submissions lead to small delays  IGTs may set up supply points retrospectively  xoserve cannot backdate the start of an LMN  xoserve LMN start date will at the earliest be date of receipt + 8 business days  xoserve process site onto Gemini system at D+8 – per NExA Annex A  Rejections will lead to further delays to the LMN start date  Start date delayed while rejections investigated and reprocessed

5. 5 Proposed solutions  In an ideal world, LMN start dates would match IGT supply point start dates  To move towards this:  Understand and address operational issues to reduce, if not remove, mismatches  If the industry accepts that dates will never match exactly, and to address historic mismatches:  Agree a “read window” to be applied to rec periods

6. 6 Address operational issues  Understand IGT SPA processes  Are shippers required to give 15 days’ notice for transfers of ownership; 8 with a withdrawal?  IGT UNC section Part C 12.7 contains these timescales  IGTs can specify a required start date within the D01 file  If enough notice was given to account for Gemini processing (and the record was accepted), this could enable the start dates to match exactly  Industry work to reduce rejections  Reducing rejections will reduce delays to start times

7. 7 Agree a read window to be applied to rec periods  DN UNC (Section M 3.8.3) allows for a transfer read to take place within a read window around the transfer date – between D-5 and D+5.  xoserve would suggest a similar read window could be applied to CSEPs reconciliation  The window would be extended to account for the 8 day period given to xoserve to make updates  This would give a read window of D-13 to D+13  (All days are working days)

8. 8 Suggested process  Rec file received from IGT containing start date D  xoserve system holds start date D+10 for LMN  xoserve system accepts rec period as start date is within the read window  xoserve system applies the provided volume to the LMN dates, ie from start date D+10 (to match LMN date and deemed period)  If the actual volume period fell outside of the 27-day window, the file would be rejected back to the IGT to discuss with the shipper

9. 9 Larger mismatches  Proposed window accounts for small mismatches caused by process timescales  It is feasible to have mismatches of months  The decision to apply the volume for period A against deemed period B, where significantly different, cannot sit with xoserve  xoserve could potentially “override” the read window but this would need to be upon instruction from the IGT  Such mismatches would need to be rejected back to IGTs for discussion with the shipper

10. 10 Rejections out of the read window IGT reviews with shipper Suggestion 2: IGT resubmits with existing data, asking xoserve to “override” read window Suggestion 1: IGT amends dates and resubmits IGT submits rec using new dates Shipper agrees to apply volume against xoserve LMN dates? Reads available for xoserve LMN dates? IGT receives rejection from xoserve