Post on 25-Dec-2015
Panel Meeting 196
12 April 2012
Apologies
Andrew Pinder
12 April 2012
Report on Progress of Modification
Proposals
Adam Lattimore
12 April 2012
4
Modifications Overview
New P282, P283
Assessment P272, P274, P276, P280, P281
Report P275, P277, P278
With Authority
-
Authority Determined
-
5
Modifications Overview
Mod. Title IWA Assessment ReportPanel
Recommendation
Ofgem Decision
Decision By
Impl. Date
Decision By
Fall Back Impl. date
P272
Mandatory Half Hourly Settlement for Profile Classes
5-8
09-Jun-11 13-Sep-12 11-Oct-12 14-Feb-1306-April-
1413-Feb-14 06-Apr-15
P274Cessation of
Compensatory Adjustments
13-Oct-11 12-Jul-12 09-Aug-12
P275Extending BSC Performance Assurance
13-Oct-11 08-Mar-12 12-Apr-12 Approve - 10 WDs - -
P276
Introduce an additional trigger
for suspending the market in the
event of a Partial Shutdown
13-Oct-11 04-May-12 14-Jun-12 28-Feb-13
27-Jun-13
P277
Allow Interconnector BM
Units to choose their P/C Status
13-Oct-11 08-Mar-12 12-Apr-12 Reject 28-May-
1228-Feb-13
27-Sep-12
27-Jun-13
P278
Treatment of Transmission
Losses for Interconnector
Users
13-Oct-11 08-Mar-12 12-Apr-12 Approve 01-May-
1201-Nov-12
28-Aug-12
28-Feb-13
P280Introduction of
new Measurement Classes
08-Dec-11
14-Jun-12 12-July-12
P281Change of BSCCo Board of Directors
& Chairman12-Jan-12 04-May-12 14-Jun-12
196/04November Release
Date
Colin Berry
12 April 2012
7
• BSC Release dates:• Last Thursday in February• Last Thursday in June• First Thursday in November
• November 12 Release date would be 1 November 2012
• Seeking to change Release date to allow technology upgrade
Introduction
8
• BSC Systems Technology upgrade:
• Initially developed and tested in 2011• Significant Oracle defects found – delayed
implementation• Oracle has fixed defects now• Cannot restart technology upgrade before June 12
Release work completes• Technology upgrade complete in September 2012• Required to ensure BSC Systems fully supported
Technology Upgrade
9
• Scope of Release:• No Approved Modifications to date• No approved Change Proposals to date• P278 targeted at Release • Four Change Requests
• P278• Impacts SAA software• Requires 10 week project• Earliest implementation date 29 November
• November 12 Release date – propose change to 29 November
November 12 Release
10
The BSC Panel is invited to:
• NOTE the rationale to change the November 12 Release implementation date
• AGREE that the November 12 Release implementation date be changed to 29 November 2012
November Release: Recommendations
196/05P275: ‘Extending
Performance Assurance’
Melinda Anderson
12 April 2012
12
Issue:• P275 argues that the Code implies the PAB acts only for Trading
Parties
• This would mean that PAB would not resolve issues for BSC Parties that are not Trading Parties (e.g. LDSOs) even though they rely on Settlement data and processes for a number of business purposes
• This is not the case
Solution:• P275 solution is to add a paragraph to Section Z to clarify the
relationship between the PAB and all PAPs with respect to Z1.6.1
• Code-only change; scope of Performance Assurance unaffected
P275: Issue and solution
13
• No impact on Applicable Objectives (a), (b), (c) and (e)
• The Panel unanimously agreed with the Workgroup’s majority view that P275 would better facilitate Objective (d) because increased BSC clarity promotes efficiency in the BSC arrangements
• Unanimously agreed legal text
• Unanimously agreed Self Governance
• Unanimously supported implementation dates• 16WD if Self Governance or• 10WD following Authority decision
P275: Panel’s initial views
14
• No new arguments were presented
• Majority support for Panel’s initial recommendation
• Unanimous support for Implementation Date
• Unanimous support for Self Governance
• One comment on legal drafting• It does not deliver the original intent of Modification but delivers the
eventual intention
P275: Report Phase Responses
Agree? Yes No
Approve P275 5 1
Implementation Date 6 0
15
The BSC Panel is invited:
• NOTE Draft Modification Report
• CONFIRM views on Applicable BSC Objectives
• CONFIRM that P275 meets Self-Governance Criteria
• APPROVE P275
P275: Recommendations (1 of 2)
16
• APPROVE Implementation Date:• 16 WD after approval or• 10WD after Authority decision
• APPROVE BSC legal text
• APPROVE Self-Governance Modification Report
• NOTE appeal window closes 15WD after ELEXON’s notification of the Panel’s decision (3 May 2012)
P275: Recommendations (2 of 2)
196/06P277: ‘Allow Interconnector
BM Units to choose their P/C Status’
David Kemp
12 April 2012
18
• Energy entering GB over Interconnector assigned to different Account to energy leaving GB
• Applicable to both transit flows and flows starting/ending in GB
• Without ECVN, in net imbalance even though net volume is zero
P277: Issue
IFA
Moyle
100MW into GBAllocated to P
AccountPaid SSP
100MW out of GBAllocated to C
AccountCharged SBP
19
• Single BM Unit per Interconnector per User• Lead Party can elect P/C Status of these BM Units
• Allows Party to net import over one Interconnector and export over another• Volumes would not net to zero, due to transmission losses
• Solution would be mandatory
P277: Solution
20
• Relevant Objectives are (c) and (d) – no impact on (a), (b) and (e)
• Majority – does not better facilitate (c) and (d):• Unduly discriminatory (c)• Current arrangements not barrier to entry (c)• Wouldn’t improve efficiency (d)
• Minority – does better facilitate (c) and (d):• Interconnectors already treated differently (c)• Precedent for different treatment (c)
P277: Panel’s initial views on:Applicable Objectives
21
• Legal text consulted on during Assessment• One minor comment made – amendment made accordingly
• Drafting for BSCPs 15, 31 & 65 and CRA SD prepared during Assessment• Not consulted on during Assessment
• Panel unanimously agreed drafting for Report consultation
P277: Panel’s initial views on:legal drafting
22
• Unanimous Panel support for proposed Implementation Dates:• February 2013 Release• Fall-back June 2013 Release
• Driven by East-West Interconnector
P277: Panel’s initial views on:Implementation Date
23
• No new respondents• No new arguments raised• Majority support for Panel’s initial recommendation• Unanimous support for Implementation Date• No comments on legal drafting
P277: Report Phase Responses
Agree? Yes No
Reject P277 6 2
Implementation Date 8 0
Changes to Code and CSDs 6 0
24
The BSC Panel is invited to:
• NOTE the P277 Draft Modification Report and the Report Phase Consultation responses;
• CONFIRM the recommendation to the Authority contained in the P277 draft Modification Report that P277 should not be made;
P277: Recommendations (1 of 2)
25
• APPROVE an Implementation Date for P277 of:• 28 February 2013 if an Authority decision is received on or
before 28 May 2012; or• 27 June 2013 if an Authority decision is received after 28 May
2012 but on or before 27 September 2012;
• APPROVE the BSC legal text for P277;
• APPROVE the changes to BSCP15, BSCP31, BSCP65 and the CRA Service Description for P277; and
• APPROVE the P277 Modification Report.
P277: Recommendations (2 of 2)
196/07P278: ‘Treatment of
Transmission Losses for Interconnector Users’
David Kemp
12 April 2012
27
• BSC allocates transmission losses to Interconnector BM Units
• Anomalous in light of ITC scheme• Compensates TSOs for National losses caused by cross-border
flows• National Grid passes through compensation to generators and
Suppliers through TNUoS• Compensation can be positive or negative
• Interconnectors should not be subject to additional network charges
• GB arrangements need to comply with European legislation
P278: Issue
28
• Set TLM to 1 for Interconnector BM Units• BSC to no longer adjust Interconnector BM Unit Metered
Volumes for any GB transmission losses• BSC would still allocate total GB transmission losses
proportionally across all other types of BM Unit
• Interconnector BM Units account for 2% of losses• Low materiality – volatility of losses can exceed this amount
P278: Solution
29
• Relevant Objectives are (a), (c) and (e) – no impact on (b) and (d)
• Majority – better facilitates (a), (c) and (e):• P278 most proportionate solution to demonstrate compliance
• Minority – does not better facilitate (a), (c), and (e):• Undue discrimination (c)• May not be needed
P278: Panel’s initial views on:Applicable Objectives
30
• Legal text consulted on during Assessment• No comments received
• Panel unanimously agreed drafting for Report consultation
P278: Panel’s initial views on: legal drafting
31
• Unanimous Panel support for proposed Implementation Dates:• November 2012 Release• Fall-back February 2013 Release
• Driven by lead time for changes to central systems
P278: Panel’s initial views on:Implementation Date
32
• No new respondents• No new arguments raised• Majority support for Panel’s initial recommendation
• One respondent was unsure
• Unanimous support for Implementation Date• No comments on legal drafting
P278: Report Phase Responses
Agree? Yes No
Approve P278 6 0
Implementation Date 7 0
Changes to Code 6 0
33
The BSC Panel is invited to:
• NOTE the P278 Draft Modification Report and the Report Phase Consultation responses;
• CONFIRM the recommendation to the Authority contained in the P278 draft Modification Report that P278 should be made;
P278: Recommendations (1 of 2)
34
• APPROVE an Implementation Date for P278 of:• November 2012 if an Authority decision is received on or
before 1 May 2012; or• 28 February 2013 if an Authority decision is received after 1
May 2012 but on or before 28 August 2012;
• APPROVE the BSC legal text for P278; and
• APPROVE the P278 Modification Report.
P278: Recommendations (2 of 2)
196/08P282: ‘Allow MVRNs from
Production to Consumption or Vice
Versa’David Kemp
12 April 2012
P282 Allow MVRNs from Production to Consumption or
Vice Versa Nigel Cornwall
For Statkraft
37
Metered Volume Reallocation Notifications
Dual trading accounts are key feature of Neta market template– designed to ensure larger, vertically integrated players
could not enjoy netting benefit MVRNs have from outset provided valuable
flexibility for licensed parties to– consolidate generation or consumption volumes
horizontally– in effect avoid active day-to-day participation in central
trading arrangements An unnecessary restriction exists, which P282
seeks to remove – this prevents energy from Production BM Units being
transferred to Consumption Energy Accounts and vice versa
38
MVRN restriction
% volume or MWh
Trading charges
Consumption Consumption
Production Production
Lead Party
BM Unit
Subsidiary partyEnergy Account
39
Defects
The current restriction:– is ineffective in its original assumed aim
• competitive restrictions should be matter for regulation– e.g. mandatory auctions
– inappropriately restricts participants’ ability in managing imbalance risk
• denies organic commercial choices• imposes cost
– unnecessarily complicates the trading arrangements– creates an inequity with embedded generation
• can consolidate against demand • also sits uncomfortably with trading unit concept
– treats trading parties differently from system operator– may not be in line with European practice
40
Key benefits of P282
Additional flexibility to manage imbalance risk, particularly for smaller participants to consolidate positions– increases efficiency
• reveals true imbalance– competitive benefits
• benefits relative to off-take market
Levels playing field with embedded generation– P100 de facto acknowledged desire to stimulate
competition and permit consolidation Reduces complexity of trading arrangements and
costs of compliance– especially with regard to contract notification process– credit?
41
Against BSC relevant objectives
c) (facilitating competition) - significantly, through additional flexibility to manage imbalance exposure to own circumstances and strategies. Risk reduction increases competition and encourages new entrants
d) (efficiency in arrangements) – removing an unnecessary restriction and helping trading parties manage their own costs
e) (European compliance) - may harmonise arrangements with those in Europe (P277 workgroup)
Issues
Working group invited to consider:– if restriction should remain for participants over a
certain size e.g. 20TWh annual production or consumption
– single energy account alternative?– allow flag switching?
Targetted and proportionate relative to alternatives
42
43
• Allow MVRNs from Production BM Units to Consumption Energy Account or vice versa• Would also allow a Party to MVRN energy from their
Production BM Units to their own Consumption Energy Account or vice versa
P282: Modification Proposal
44
• What changes are needed to support the proposed solution?
• What wider impacts would the proposed solution have?
• How would GB’s two-Account arrangements be affected?
• What benefits would Parties gain from P282?
• What meaning would ‘Production’ and ‘Consumption’ hold?
• What are the benefits to the Applicable BSC Objectives?
P282: Things to consider
45
• Recommend: 6-month Assessment Procedure (11 October 2012)
• Workgroup membership should include:• Members of Settlement Standing Modification Group (SSMG)• Any other relevant experts and interested Parties
• 6 months needed to allow:• Full assessment of wider impacts, including detailed analysis • Full consideration of wider implications• 20WD Industry IA and 15WD consultation• Avoiding Workgroup meetings during London 2012 Olympics
P282: Proposed progression (1 of 2)
46
• Proposer believes no link with any current SCRs• Possible interactions with Cash-Out SCR
• Proposer is not requesting Self-Governance• Material impact on existing arrangements
P282: Proposed progression (2 of 2)
47
The BSC Panel is invited to:
• DETERMINE that Modification Proposal P282 progresses to the Assessment Procedure;
• AGREE the Assessment Procedure timetable such that an Assessment Report should be completed and submitted to the Panel at its meeting on 11 October 2012;
P282: Recommendations (1 of 2)
48
• DETERMINE that the P282 Workgroup should be formed from members of the Settlement Standing Modification Group (SSMG), supplemented with any other relevant experts and interested Parties;
• AGREE the Workgroup’s Terms of Reference;
• AGREE that P282 has no interaction with any on-going SCRs; and
• AGREE that P282 does not meet the Self-Governance Criteria.
P282: Recommendations (2 of 2)
196/09Recommendation to raise a
Modification Proposal: ‘Reinforcing the
Commission of Metering Equipment Process
Dean Riddell
12 April 2012
50
• Metering Equipment subject to commissioning process (CoP4)• Metering System Registrant responsible• Typically discharged via appointed Meter Operator Agent
(MOA)• Intended to prove accuracy of metering and detect problems• Failure may mask significant issues (unlikely to be detected
later)
• Technical Assurance of Metering Expert Group (TAMEG) and ELEXON concerns• Certain Metering Equipment usually not within
Registrant/MOA control when commissioning required• Issues prevent proper commissioning and lead to incomplete
records
Background
51
• Solution principles agreed by TAMEG• Make relevant System Operator responsible for
• Commissioning Current Transformers and Voltage Transformers• Providing relevant certificates and commissioning records
• Require MOA to assess performance and notify Registrant of potential issues (Registrant retains overall responsibility)
• Require Registrant to consult relevant System Operator and agree steps to minimise risk of issues
• Workgroup to develop and confirm solution detail and outstanding areas based on TAMEG work
Proposed Solution
52
• Solution developed by the TAMEG is basis of Proposed Solution
• Develop Proposed Modification (some specific areas identified)
• Treatment of test certificates and results• Materiality of issue and potential benefit• Retrospection/legacy issues are out of scope• Standard areas
• Assess Proposed Modification (and develop any Alternative) against Applicable BSC Objectives
• Establish impacts and costs• Develop BSC legal text• Consult BSC Parties and other participants and• Recommend Implementation Date and approach
Areas to consider
53
• Recommend five month Assessment Procedure (12 September Panel)• Three Workgroup meetings• Develop and assess Proposed Solution• If Alternative Solution raised, develop and assess• 15WD industry impact assessment and 15WD consultation• We will submit to Panel earlier if possible
• Workgroup membership• Members of the TAMEG• Members of the Volume Allocation Standing Modification Group
(VASMG)• Any interested parties
Proposed progression (1 of 2)
54
• No links with any current Significant Code Review
• Self-Governance not requested
• Believe Modification does not meet Self-Governance Criteria• Implementation would materially affect participants’ activities
(Metering System Registrants, System Operators and MOAs)
Proposed progression (2 of 2)
55
The BSC Panel is invited to:
• RAISE requested Modification Proposal (Attachment A)• NOTE IWA• SUBMIT the Modification to Assessment Procedure• AGREE five month Assessment Procedure timetable• AGREE basis for Workgroup membership• AGREE Workgroup’s Terms of Reference• AGREE the Modification has no SCR interaction• AGREE the Modification does not meet Self-Governance
Criteria
Recommendations
Minutes of Meeting 195 & Actions Arising
Adam Richardson
12 April 2012
Chairman’s ReportBSC Panel
Andrew Pinder
12 April 2012
ELEXON ReportBSC Panel
Victoria Moxham
12 April 2012
Verbal update on issues loading LLF
data into SVAA
Caroline Wright
12 April 2012
60
• SVAA load of 2012/13 LLF data for the 2012-13 BSC Year system produced exceptions:• SVA LLFCs that were not registered in MDD • LLFCs registered in MDD with no associated LLFs
• 8 LDSOs out of 19 impacted
• Issue 1: 4 LDSOs had not submitted required MDD change requests
• Issue 2: 4 LDSO had re-submitted SVA LLF files which were not processed by ELEXON
What was the issue ?
61
• Impacted LDSOs contacted: • Instructed to provide MDD change request for May MDD
release; or• Notified that we still needed to process their SVA files
• Impacted HHDAs advised not to download outdated files from 4 LDSOs until latest version on the Portal• Files loaded on 4 April 2012• All HHDAs confirmed that they have downloaded the correct
files
• Informed the SVG and the ELEXON Board
• Default LLFs used for impacted MSIDs in II credit calculations 1 April – 3 April 2012 • No discernible impact on levels of Energy Indebtedness and
required Credit Cover
What did we do and what is the impact?
62
• Internal investigation to understand process failure
• Report back to the SVG, Board and Panel with outcome report and recommendations as appropriate
Next steps
Smart Update
Chris Rowell
12 April 2012
64
&
Smart Metering: Consultations & Conclusions
DCC Licence P116+ Q14
DCC Licence Application Regulations P116+ Q4
Data Access & Privacy P97 Q30
Consumer Engagement Strategy P92 Q36
Smart Energy Code P160 Q63
1 Jun
1 Jun
1 Jun
Updated Impact Assessments
15 Ma
y
1 Jun
Programme Update (P13)http://www.decc.gov.uk/assets/decc/11/consultation/smart-metering-imp-prog/4938-smart-metering-imp-prog-update-apr2012.pdf
DECC response to 2011 consultations on Licence Conditions & Installation CoP
EC notification of SMETS v1.0
65
Decisions!
Rollout (domestic & smaller non domestic)
• to complete by 31 December 2019• no exemptions for early (non compliant) meter installations
Technical Specifications
• SMETS v1.0 – European Commission ‘shortly’• Communications technology not specified (HAN & WAN) v1.0
compliant meters will count to rollout target• Suppliers responsible for v1.0 equipment assurance
Consumer Protections
• Licence obligation for compliance with Installation CoP• No sales during installation• Data collection: monthly (any purpose) – daily (regulated
purposes – consumer opt out) – HH or marketing (consumer opt in)
66
SEC Content
Section Activity
Participation • Party types• Accession rules
Using DCC Services• Enrolment/withdrawal of meters• DCC’s Comms Services• DCC Charges
Governance & Change
• SEC Relevant Objectives• SEC Panel• Code Administrator & Secretariat• Mods Process• Reporting
Assurance & Enforcement
• Compliance & Assurance• Liabilities• Disputes• Suspension & Expulsion
Other Matters• Intellectual Property Rights• Confidentiality• Transfer of DCC Licence• Force Majeure/Business Continuity
1 Jun
Voting Members 4 x large Suppliers 1 x small Supplier 1 x gas transporter 1 x electricity distributor 2 x other DCC comms users up to 2 consumer reps 1 SEC Panel chair appointee 1 SEC Panel chair
Non Voting Members 1 x DCC appointee
Non Voting Attendees 1 x Authority appointee 1 x Government appointee
67
Privacy & Data Access Proposals
User Access
Consumer • Access via HAN• Access via Supplier
Suppliers• Monthly Data capture for all uses• Daily Data capture for all uses except marketing (with
opt-out)• > Daily or for marketing needs consumer opt-in
NetworksOptions• As per Supplier• HH access subject to networks developing plans for
approval that demonstrate protection of privacy
Third Parties • Data via consumer consent• Can be via DCC, subject to meeting SEC rules
Non Domestic premises • DECC will consider if any proposals are required
Settlement • No specific provisions for Settlement but will consider
how privacy framework could change if Settlement changes
1 Jun
68
Consumer Engagement Strategy & Tools
Indirect Feedback
Direct/ Real Time Feedback
Motivational
Campaigns
Advice & Guidance
Central Delivery Body?
1 Jun
Help consumers make energy savings
Ensure vulnerable / low
income get benefits
Build support & address
concerns
69
Licence Application Regulations
4 stage tender exercise• Qualification• Proposal• Best and Final Offer• Preferred Applicant
DCC Licence & Licence Application Regulations
15 Ma
y
Draft Licence
Copious detail as per other licences…
1 Jun
70
Smart BudgetFull Year 2011/12
Released Funds
£ ,000
Spend this month
£ ,000
Full Year
£ ,000
Smart Support 464 39 256
Smart Opportunities 36 0 19
TOTAL 500 39 275
Distribution Report
David Lane
12 April 2012
National Grid Report
Ian Pashley
12 April 2012
Ofgem Report
Jon Dixon
12 April 2012
Accepting Modification Proposals
Adam Richardson
12 April 2012
76
If there’s no Defect in the BSC the
Modification is invalid and should be
rejected?
Should the cost of assessing Modifications
be a factor when determining if or how
they should be progressed?
Recent Modifications: Concerns Arising
Complex Modifications
with many potential
solutions should be considered as Standing Issues
instead?
Does proposer ownership mean the
proposer should dictate the process
and progression timescales for Modifications?
Can ELEXON or the BSC Panel
reject a Modification or force it to be withdrawn?
77
Obligations & Governance
The BSC Panel
Panel Objectives (B1.2.1)
• Require Panel to give full and prompt effect to the BSC consistent with achieving the BSC objectives and in a transparent, economic, efficient and non-discriminatory way
Panel Modification Responsibilities (F1.2.1 & F1.2.2)
• Operate Mods in efficient, economical and expeditious manner
• Take account of complexity and urgency
• Ensure Code facilitates achievement of the Applicable BSC Objective(s)
• No undue discrimination between BSC Parties or classes of Party
• Consistent with Code Administration Code of Practice
78
Obligations & Governance
The Code Administrator
Code Administration Code of Practice
• Twelve Principles…
• Principle 1: Code Administrators shall be critical friends
• Principle 5: Code Administrators shall support processes which enable users to access a ‘pre-Modification’ process to discuss and develop Modifications
The BSC Panel
79
Obligations & Governance
The Code Administrator
Modification
Discuss Issue
Modification
SecretaryTo
Authority
Modification Workgroup(Issue Group)
The BSC Panel
Standing Issue
80
Obligations & Governance
The Code Administrator
Modification
SecretaryModification
Standing Issue
Discuss Issue
To Authorit
yModification Workgroup(Issue Group)
The BSC Panel
81
• The BSC and BSCP40
• Help Desk Queries
• Direct Contact
• Web-pages:
• Guidance Notes
• Process Diagrams
• Groups and Forums – E.g.
• Panel Committees (ISG, SVG)
• Expert Groups (PSRG, TAMEG)
• Cross Codes Forum etc.
Help and Support Available
Discuss Issue
F1.2.4A requires BSCCo to provide assistance in relation to Modifications including assistance with drafting a Modification Proposal
82
• To be accepted by the Modification Secretary a Modification Proposal must contain (F2.1.2):
• Name of Proposer & Proposers Rep
• Description of issue or defect
• Description of nature / purpose of Mod
• Indication of Code Sections to be amended (& nature of amendment)
• Rationale why Proposer believes Mod would better facilitate achievement of the Applicable BSC Objective(s)
• Indication of impact on Core Industry Documents
• Indication of impact on BSC Systems / Party’s systems & processes
• Rationale for urgency/self governance/exemption from SCR
What is a “Valid” Modification?
• Description of issue or defect
83
• The scope of the BSC is defined in Condition C3.2 of NGET's Transmission Licence, which defines the 'balancing and settlement arrangements'
• Definition is short & unspecific and may be construed widely
• It must be taken to encompass everything currently in the BSC
What is a valid “Issue” or “Defect”?
Unless a proposed Modification is wholly unrelated to balancing, imbalance determination or settlement it is likely to be difficult to conclude with certainty that it falls outside the scope in C3.2.
New things can be introduced into the BSC so long as they fall within the scope of C3.2.
85
• Issues may arise when it is unclear if all of the Modification Proposal falls within C3.2, but part of it does
• In this case it is arguable that the Modification Proposal would change the BSC into something of which at least part was still contemplated by C3.2, and therefore the BSC Panel must progress it through the Modifications Process in Section F of the BSC
Previous Legal Advice on C3.2
C3.2 The balancing and settlement arrangements encompass matters relating to:
a) bids or offers to adjust quantities of electricity on the total system
b) assisting licensee in coordinating & directing the flow of electricity onto & over the national electricity transmission system
c) aiding licensee balancing national electricity transmission system
d) the allocation of the quantities of electricity to BSC Parties
e) the settlement of financial obligations between BSC parties
86
• Two Considerations:
1. Valid Mod: Over-rule acceptance / rejection of Modification Proposal by the Modification Secretary (based on compliance with F2.1.2)
2. Related Mods: Refuse to accept the Modification Proposal if it has substantially the same effect as a Pending Modification or a Modification that has been rejected within the past two months (F2.1.4). (The Authority can overrule this BSC Panel decision.)
Acceptance of Modification Proposals by the BSC Panel
The BSC Panel is not entitled to decline to process a Modification Proposal on any of the grounds for which the Authority might not
approve a Modification Proposal.
These are matters for the Authority. The BSC Panel may express a view on such issues but it cannot exclude a proposal from being processed on these grounds.
87
• Proposers Own their Modification & can amend Proposed Solution
• Proposers may withdraw their Modification prior to the Workgroup reporting its recommendations to the Panel
• Modification Workgroups can derive an Alternative Solution
BUT THE PANEL OWNS THE PROCESS
• The Panel may require a Modification Proposal to be withdrawn at any time if the Proposer of that Modification is deliberately and persistently disrupting or frustrating the work of the Workgroup and that Modification Proposal shall be deemed to have been so withdrawn (F2.1.12A).
A Word on Proposer Ownership
88
• Pre-Mod advice
• Concern over governance issues it might create
• Shaping of mod
• Ultimately rejected
Case Studies
P264 Two-thirds majority requirement for Panel recommendations on licence originated Modifications
89
• Pre-Mod advice
• Explanation of how issue currently addressed
• Proposer seeking clarification
• We would have recommended rejection
• Ultimately withdrawn
Case Studies
P264 Two-thirds majority requirement for Panel recommendations on licence originated Modifications
P267 Consideration of wider industry developments & duration of changes when agreeing progression timetables
90
• Pre Mod advice
• Consideration of implications
• Shaping of mod
• Advice it should be taken forward as an issue
Case Studies
P264 Two-thirds majority requirement for Panel recommendations on licence originated Modifications
P267 Consideration of wider industry developments & duration of changes when agreeing progression timetables
P274 Cessation of Compensatory Adjustments
91
• Pre-Mod advice
• Explanation of custom and practice
• Proposer seeking clarification
• We agreed that the BSC was not clear
• Ultimately a simpler change than proposer anticipated to cement existing custom and practice
Case Studies
P264 Two-thirds majority requirement for Panel recommendations on licence originated Modifications
P267 Consideration of wider industry developments & duration of changes when agreeing progression timetables
P274 Cessation of Compensatory Adjustments
P275 Extending the Performance Assurance Framework
92
If there’s no Defect in the BSC the
Modification is invalid and should be
rejected?
Recent Modifications: Concerns Arising
»It should be rejected if the defect or issue is wholly outside the scope of balancing and imbalance settlement (but this may be difficult to demonstrate).
93
Should the cost of assessing Modifications
be a factor when determining if or how
they should be progressed?
Recent Modifications: Concerns Arising
»No. The Panel must progress all Modification Proposals brought before it on an equitable basis without undue discrimination, taking account of the complexity and urgency of the proposal.
94
Recent Modifications: Concerns Arising
Complex Modifications
with many potential
solutions should be considered as Standing Issues
instead?
»ELEXON encourages this when discussing issues and ideas regarding prospective Modification Proposals with Parties. But it is ultimately up to the Proposer whether to raise a Modification or Standing Issue.
»The BSC Panel may send Modifications with ill-defined solutions into a “Definition” phase.
95
Recent Modifications: Concerns Arising
Does proposer ownership mean the
proposer should dictate the process
and progression timescales for Modifications?
»No. The Proposer can only dictate the Proposed Solution. The Panel is the guardian of the Process.
The changing landscape: the
impact of the European Union
Steve Wilkin
12 April 2012
97
Bid-Offer Acceptances
& BMRS?
Bid-Offer Acceptances
&Settlement
Payments
The Future: EU Initiatives
REMIT(Regulation on Energy
Market Integrity & Transparency)
MiFID II Exemption
(Markets in Financial Instruments Directive)Balancing,
Settlement, Market
Coupling, &Data
Exchange
Network Codes(particularly Balancing)
Third Package(Single European Market)
Comitology Guidelines
(Data Transparency)
EMIR, MAD, etc(European Market
Infrastructure Regulation, Market Abuse Directive,
etc)
Single Energy Market by 2014 Fallout from financial crash in 2008
Key players with formal roles:
• Commission decides what areas need to be covered and drives process:• Framework Guidelines
drafted by ACER (and approved by Commission)
• Network Codes drafted by ENTSO-E (and approved by Commission)
• Commission presents to Ministers for approval (‘comitology’)
• Then legally binding
Process Followed to develop Network Codes
3 year plan for electricity Network Codes: http://ec.europa.eu/energy/gas_electricity/codes/codes_en.htm
The European Electricity Target Model
(diagram from ENTSO-E)
Congestion Management and Capacity Allocation (CACM)Network Code
Balancing Network Code
CACM Network Code:
•ENTSO-E live consultation on draft Network Code – closes 23 May: https://www.entsoe.eu/resources/network-codes/capacity-allocation-and-congestion-management
•Potential BSC impacts: timing of Gate Closure; market splitting
•Plan to have legal Network Code finalised by end 2013
Potential BSC impacts & some current events (1)
Balancing Framework Guidelines:•ACER Consultation from end April? (ACER Home page: http://www.acer.europa.eu/portal/page/portal/ACER_HOME)
•Potential BSC impacts: Balancing Mechanism and payments; imbalance settlement and pricing
•Plan to have legal Network Code finalised by end 2014
Ofgem consultation on implementing the EU Target Model in GB:
•http://www.ofgem.gov.uk/Pages/MoreInformation.aspx?file=EU%20Target%20Model%20open%20letter.pdf&refer=Europe
•Workshop 30 April and consultation closes 22 May
Potential BSC impacts & some current events (2)
Industry and UK Influence(also trade associations, stakeholder events,
consultations)
JESG
NGET, Ofgem,
industry and ELEXON
Network Code Drafting Comitology(political agreement)
DECC/OfgemStakeholder
Group
DECC, Ofgem, NGET, industry
and ELEXON
Framework Guidelines
Any Other Business
12 April 2012
Next Meeting:10 May 2012