BSC Panel 214 11 July 2013. Report on Progress of Modification Proposals Adam Lattimore 11 July 2013

BSC Panel 214

11 July 2013

Report on Progress of Modification

Proposals

Adam Lattimore

11 July 2013

3

Modifications Overview

New P294, Issue 48

Definition -

Assessment P283, P291, Issue 46, Issue 47

Report P293

With Authority

P272, P286, P292

Authority Determined

-

Self-Gov Determined

-

214/04P295 ‘Submission and

publication of Transparency

regulation data via the BMRS’

Talia Addy/Tariq Hakeem

11 July 2013

P295 – Transparency Regulation

Tariq Hakeem - National Grid

6

P295 - Issue

Regulation No 543/2013 (Transparency Regulation) has come into force

with an implementation date of 4th 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

7

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

8

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

9

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

10

• 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

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• 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)

12

• 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)

13

• 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

14

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

214/05Request 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

16

• 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

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• 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

18

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

19

• 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

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• 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

21

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

214/06P283 ‘Reinforcing the

Commissioning of Metering Equipment

Processes’

Claire Anthony

11 July 2013

23

• 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

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• 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)

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• 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)

26

• 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)

27

• 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


28

• 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)

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• 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)

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• Panel invited to confirm its views that P283 would better facilitate Applicable BSC Objectives (b), (d) and (c)?

P283: Panel’s Final Recommendations

31

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)

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• 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


P291 ‘REMIT Inside Information

Reporting Platform for GB Electricity’

David Kemp

11 July 2013

214/07

34

• 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)

35

• 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)

36

• 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

37

• 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


38

• 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


39

• 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


Question Yes No Neutral

Other

Agree Approve? 6 0 1 01 of 2

40

• 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



Other

Agree Approve? 6 0 1 02 of 2

41

• Several comments received on legal text

• Some amendments made to improve clarity



Other

Agree Changes to Code? 5 0 0 2

42

• General agreement with Implementation Date• Welcome decision to align with Transparency regulation



Other

Agree Implementation Date? 6 0 0 1

43

• 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

44

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]


45

• 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.


Minutes of Meetings 213 & Actions Arising

Adam Richardson

11 July 2013

Chairman’s ReportBSC Panel

Andrew Pinder

11 July 2013

214/01ELEXON 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

214/08Coordination 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

62

• 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

63

• 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

65

• TAA / BSC Auditor Annual Report• Action to investigate approach

Progress• Input from:

• PAB• TAA• Metering Experts

Background

66

• 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

67

• Number of work-streams1. Guidance & Education for Industry

• Best Practice• Impact - £’s & Settlement• Responsibilities (P283)• Accountabilities

2. New mechanisms3. 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

68

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

70

• Go Live - 1 April earlier this year.

• SLAs / Feedback• • Final Acceptance & Project closure

• Excellent team work

• Communicating to our customers

Procurement update

71

We invite the Panel to:

• NOTE the verbal update on the implementation of the TAA contract.

Recommendations

214/10Moving to ‘User Pays’

billing for Data Transfer costs and

development of the ELEXON Portal to

deliver DTS FlowsNeil Tingay

11 July 2013

73

• 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

74

• 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

75

• 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.

78

• 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

Documents

BSC Panel 214 11 July 2013. Report on Progress of Modification Proposals Adam Lattimore 11 July 2013